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of <h1>Section 438 allows tax authorities to set off refunds and temporarily withhold refunds with written intimation and approvals</h1> Section 438 authorises tax authorities to set off refunds against a taxpayer's outstanding liabilities and to withhold refunds for up to sixty days where assessment or reassessment is pending; set-off requires prior written intimation to the taxpayer, and withholding requires reasons recorded in writing plus prior approval of the Principal Commissioner/Commissioner. The Bill's earlier text used slightly different wording (e.g., insertion of 'only' and shorter cross-references) but those differences are stylistic and do not materially change operation. Taxpayers should preserve intimations, written reasons and approval records to challenge or verify set-off or withholding actions.
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