The CPC gave me a section 245 intimation saying I had 21 days to respond, then adjusted my whole refund the very next day against a demand for a year that is under appeal. What do I actually get back, and do I get interest?
You get back everything adjusted in excess of 20 per cent of the disputed demand, but on these facts you get no interest on it. The Calcutta High Court held that adjusting the refund one day after issuing a 21-day section 245 intimation was a clear breach of the power to adjust and an abject violation of the law governing section 245, and directed refund of the excess over 20 per cent within eight weeks — but refused interest because the assessee had waited about two years before coming to court, and refused to touch an earlier adjustment made three years before the writ petition on the ground of laches.
Decided by the High Court (Om Narayan Rai J) on 2026-05-04, reported as WPO 780 of 2025; 2026:CHC-OS:153 (Calcutta High Court, Original Side). It bears on section 245, section 220(6), section 143(1), section 246A of the Income Tax Act 1961, in Refunds, Interest & Condonation, Demand, Recovery & Stay and Appeals matters.
This is the entry the practitioner needs after Court On Its Own Motion and Jindal Stainless, because it answers the question those do not: what is the remedy. The answer here is restitution of the excess over 20 per cent, not a mere direction to re-do the intimation — but restitution stripped of interest, and stripped altogether as to any adjustment older than three years. Delay is therefore the assessee's real enemy, and the judgment prices it. Three further things make it valuable. First, it is candid that the 20 per cent is a ceiling on adjustment and not a floor on relief: the excess comes back, the 20 per cent stays, and the whole direction is expressly made subject to the outcome of the pending appeal. Second, it takes a position against the Rajasthan High Court in Rajendra Kumar, which the library already carries: the Calcutta High Court respectfully disagreed with the proposition that once an appeal is filed in time the assessee is not in default, reasoning that if that were so section 220(6) would have nothing to operate on and the 20 per cent requirement would be pointless. A practitioner leading Rajendra Kumar in Calcutta must know this. Third, it disposes of two defences the Department now runs routinely — that not responding to the outstanding demand on the portal dashboard forfeits the right to object to a section 245 intimation (rejected: sections 143(1) and 245 operate in distinct fields and at different stages), and that the intimation itself is enough compliance (rejected, following Graphite India, and Northern Coal Fields distinguished). The countervailing point the assessee must face is paragraph 24: where no section 220(6) stay application has been filed at all, the Assessing Officer is 'quite justified' in adjusting, and the vice is only in the manner. So the remedy here is procedural and partial, not a declaration that the demand cannot be recovered.
Binding within that High Court's jurisdiction. Persuasive elsewhere.
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The petitioner, a partnership firm, filed its return for AY 2018-19 on 15 October 2018 declaring Rs 1,16,24,230. On scrutiny an order under section 143(3) read with section 144B dated 11 September 2021 assessed the total income at Rs 6,60,76,120, followed by a notice of demand. The firm appealed under section 246A on 22 September 2021 and the appeal remained pending. For AY 2021-22 it claimed a refund of Rs 7,59,274; a refund of Rs 7,58,210 was determined on 25 October 2022 and on the same day a section 245 intimation was issued informing the firm that the entire refund stood adjusted against demands for AYs 2009-10 and 2018-19. For AY 2022-23 a refund of Rs 1,64,03,820 was determined by intimation dated 27 September 2023. On 10 November 2023 the firm received a section 245 notice proposing adjustment against Rs 37,740 for AY 2016-17 and Rs 2,63,64,130 for AY 2018-19, granting 21 days to act; on 11 November 2023, the very next day, the whole of Rs 1,64,03,820 was adjusted against the AY 2018-19 demand. By letters of 8 January 2025 and 2 September 2025 the firm asked for release of Rs 1,16,96,443 adjusted in excess of 20 per cent of the disputed demand and for stay pending appeal; both went unanswered. The writ petition was filed on 27 October 2025. No application under section 220(6) had ever been made to the Assessing Officer. The Revenue relied on the Madhya Pradesh High Court in Northern Coal Fields, on Chemester Food Industry, on Gouri Sankar Awasthi and on the petitioner's own delay in filing written submissions in the appeal, and pleaded laches.
The writ petition was disposed of. The challenge to the adjustment of 25 October 2022 was not entertained, the writ petition having been filed more than three years afterwards with no explanation, that being the period within which a suit for the money would have had to be brought (para 12). The challenge to the adjustment of 11 November 2023 was entertained despite a two-year delay, because no third-party right had accrued, there was no waiver, and the adjustment was in any case subject to the pending appeal (para 13). On the merits, section 245 does not exclude natural justice, so the Revenue must issue an intimation, examine the objections and then decide whether to adjust (para 22); giving 21 days and adjusting on the following day was a clear breach of the authority to adjust (para 25) and foreclosed the right of objection that would have invoked the Assessing Officer's discretion under section 220(6) (para 26). Where no section 220(6) application has been made the Assessing Officer is justified in proceeding to adjust, but the adjustment must conform to section 245 (para 24), and in exercising the power he must keep in mind the Instruction of 2 February 1993 and the Office Memoranda of 29 February 2016, 31 July 2017 and 25 August 2017 (paras 27 and 35). The Court respectfully disagreed with Rajendra Kumar to the limited extent that it held an assessee not to be in default merely on filing an appeal in time (para 34). The Revenue was directed to refund the amounts adjusted in excess of 20 per cent of the disputed demand for AY 2018-19 pursuant to the November 2023 intimation within eight weeks, excluding from that computation the amounts adjusted on 25 October 2022, and the petitioner was held not entitled to any interest on the sum refunded because of its two-year delay (para 47). The Commissioner (Appeals) was requested to decide the appeal within two months, and the refund direction was made subject to that decision (para 48). No costs.
The Court took delay first, applying State of Madhya Pradesh v Bhailal Bhai, that the limitation period for a civil suit is ordinarily the measure of reasonable time under Article 226, together with the line from Dehri Rohtas Light Railway and Karnataka Power Corporation that laches is a rule of practice and of discretion rather than of law. That produced the split outcome: the 2022 adjustment, over three years old and unexplained, was left alone; the 2023 adjustment, within three years, was entertained because mere lapse of time creates no indefeasible right in the Revenue to retain money it was not entitled to adjust. On the merits the Court reasoned that nothing in section 245 excludes natural justice by necessary implication, so fairness requires notice, examination of the objection, and then a decision — an obligation the Revenue itself accepted in CBDT Instruction No. 12/2013 issued pursuant to the Delhi High Court's directions in the suo motu case. Adjusting on the day after a 21-day notice destroyed that scheme and, importantly, destroyed the assessee's opportunity to invoke the Assessing Officer's discretion under section 220(6), a discretion the Court held (following Aluminium Corporation of India and Kashiram Agarwalla) must be exercised judicially and not in the role of a mere tax-gatherer, and which can be exercised suo motu. The Court then worked through the competing authorities. Graphite India was applied for the proposition that a mere intimation of the proposal to adjust is an idle formality and that adjusting more than 20 per cent while disregarding the Office Memoranda is bad in law; Danieli India and Gaurav Enterprises were noted to the same effect; Sun Pharmaceutical was cited for the unfairness of unbridled adjustment. Northern Coal Fields was distinguished as a case where a conditional stay had been granted and had expired, and its observation that mere service of intimation suffices was held not to be in consonance with the settled position or with Instruction No. 12/2013; the Supreme Court's dismissal of the SLP in that case was read as an order 'in the facts of' the case. Mohan Wahi, Chemester Food and Gouri Sankar Awasthi were each distinguished on their facts. On the assessee's own authority the Court parted company with Rajendra Kumar: if filing an appeal by itself meant the assessee was not in default, section 220(6) would have nothing to operate on and no deposit of any percentage would ever be required, and Golam Momen holds that the scope of making an application is implicit in the section. Finally the Court refused the Revenue's argument that failure to contest the demand on the portal dashboard forfeited the right to object, holding that adjustments under section 143(1) and under section 245 operate in distinct fields at distinct stages and that a section 245 notice is a fresh statutory trigger overriding the dashboard status.
It is evident from records that prior intimation under Section 245 of the 1961 Act was given on November 10, 2023 allowing the assessee 21 days to respond thereto, but the refunds were adjusted on the following day itself. This constitutes a clear breach of the authority to adjust in terms of the aforementioned provision.
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Handle my notice → Ask a CA on WhatsAppYou get back everything adjusted in excess of 20 per cent of the disputed demand, but on these facts you get no interest on it. The Calcutta High Court held that adjusting the refund one day after issuing a 21-day section 245 intimation was a clear breach of the power to adjust and an abject violation of the law governing section 245, and directed refund of the excess over 20 per cent within eight weeks — but refused interest because the assessee had waited about two years before coming to court, and refused to touch an earlier adjustment made three years before the writ petition on the ground of laches. This was decided by the High Court (Om Narayan Rai J) and bears on section 245, section 220(6), section 143(1), section 246A of the Income Tax Act 1961. It is reported as WPO 780 of 2025; 2026:CHC-OS:153 (Calcutta High Court, Original Side). This is the entry the practitioner needs after Court On Its Own Motion and Jindal Stainless, because it answers the question those do not: what is the remedy. The answer here is restitution of the excess over 20 per cent, not a mere direction to re-do the intimation — but restitution stripped of interest, and stripped altogether as to any adjustment older than three years. Delay is therefore the assessee's real enemy, and the judgment prices it. Three further things make it valuable. First, it is candid that the 20 per cent is a ceiling on adjustment and not a floor on relief: the excess comes back, the 20 per cent stays, and the whole direction is expressly made subject to the outcome of the pending appeal. Second, it takes a position against the Rajasthan High Court in Rajendra Kumar, which the library already carries: the Calcutta High Court respectfully disagreed with the proposition that once an appeal is filed in time the assessee is not in default, reasoning that if that were so section 220(6) would have nothing to operate on and the 20 per cent requirement would be pointless. A practitioner leading Rajendra Kumar in Calcutta must know this. Third, it disposes of two defences the Department now runs routinely — that not responding to the outstanding demand on the portal dashboard forfeits the right to object to a section 245 intimation (rejected: sections 143(1) and 245 operate in distinct fields and at different stages), and that the intimation itself is enough compliance (rejected, following Graphite India, and Northern Coal Fields distinguished). The countervailing point the assessee must face is paragraph 24: where no section 220(6) stay application has been filed at all, the Assessing Officer is 'quite justified' in adjusting, and the vice is only in the manner. So the remedy here is procedural and partial, not a declaration that the demand cannot be recovered. If it applies to you, the first step is this: Diarise the section 245 intimation the day it arrives and file the objection within the period it grants — the whole case turned on the right to object having been activated and then foreclosed.
The petitioner, a partnership firm, filed its return for AY 2018-19 on 15 October 2018 declaring Rs 1,16,24,230. On scrutiny an order under section 143(3) read with section 144B dated 11 September 2021 assessed the total income at Rs 6,60,76,120, followed by a notice of demand. The firm appealed under section 246A on 22 September 2021 and the appeal remained pending. For AY 2021-22 it claimed a refund of Rs 7,59,274; a refund of Rs 7,58,210 was determined on 25 October 2022 and on the same day a section 245 intimation was issued informing the firm that the entire refund stood adjusted against demands for AYs 2009-10 and 2018-19. For AY 2022-23 a refund of Rs 1,64,03,820 was determined by intimation dated 27 September 2023. On 10 November 2023 the firm received a section 245 notice proposing adjustment against Rs 37,740 for AY 2016-17 and Rs 2,63,64,130 for AY 2018-19, granting 21 days to act; on 11 November 2023, the very next day, the whole of Rs 1,64,03,820 was adjusted against the AY 2018-19 demand. By letters of 8 January 2025 and 2 September 2025 the firm asked for release of Rs 1,16,96,443 adjusted in excess of 20 per cent of the disputed demand and for stay pending appeal; both went unanswered. The writ petition was filed on 27 October 2025. No application under section 220(6) had ever been made to the Assessing Officer. The Revenue relied on the Madhya Pradesh High Court in Northern Coal Fields, on Chemester Food Industry, on Gouri Sankar Awasthi and on the petitioner's own delay in filing written submissions in the appeal, and pleaded laches. The matter was decided on 2026-05-04 by the High Court (Om Narayan Rai J). On those facts the High Court held as follows. The writ petition was disposed of. The challenge to the adjustment of 25 October 2022 was not entertained, the writ petition having been filed more than three years afterwards with no explanation, that being the period within which a suit for the money would have had to be brought (para 12). The challenge to the adjustment of 11 November 2023 was entertained despite a two-year delay, because no third-party right had accrued, there was no waiver, and the adjustment was in any case subject to the pending appeal (para 13). On the merits, section 245 does not exclude natural justice, so the Revenue must issue an intimation, examine the objections and then decide whether to adjust (para 22); giving 21 days and adjusting on the following day was a clear breach of the authority to adjust (para 25) and foreclosed the right of objection that would have invoked the Assessing Officer's discretion under section 220(6) (para 26). Where no section 220(6) application has been made the Assessing Officer is justified in proceeding to adjust, but the adjustment must conform to section 245 (para 24), and in exercising the power he must keep in mind the Instruction of 2 February 1993 and the Office Memoranda of 29 February 2016, 31 July 2017 and 25 August 2017 (paras 27 and 35). The Court respectfully disagreed with Rajendra Kumar to the limited extent that it held an assessee not to be in default merely on filing an appeal in time (para 34). The Revenue was directed to refund the amounts adjusted in excess of 20 per cent of the disputed demand for AY 2018-19 pursuant to the November 2023 intimation within eight weeks, excluding from that computation the amounts adjusted on 25 October 2022, and the petitioner was held not entitled to any interest on the sum refunded because of its two-year delay (para 47). The Commissioner (Appeals) was requested to decide the appeal within two months, and the refund direction was made subject to that decision (para 48). No costs.
The Court took delay first, applying State of Madhya Pradesh v Bhailal Bhai, that the limitation period for a civil suit is ordinarily the measure of reasonable time under Article 226, together with the line from Dehri Rohtas Light Railway and Karnataka Power Corporation that laches is a rule of practice and of discretion rather than of law. That produced the split outcome: the 2022 adjustment, over three years old and unexplained, was left alone; the 2023 adjustment, within three years, was entertained because mere lapse of time creates no indefeasible right in the Revenue to retain money it was not entitled to adjust. On the merits the Court reasoned that nothing in section 245 excludes natural justice by necessary implication, so fairness requires notice, examination of the objection, and then a decision — an obligation the Revenue itself accepted in CBDT Instruction No. 12/2013 issued pursuant to the Delhi High Court's directions in the suo motu case. Adjusting on the day after a 21-day notice destroyed that scheme and, importantly, destroyed the assessee's opportunity to invoke the Assessing Officer's discretion under section 220(6), a discretion the Court held (following Aluminium Corporation of India and Kashiram Agarwalla) must be exercised judicially and not in the role of a mere tax-gatherer, and which can be exercised suo motu. The Court then worked through the competing authorities. Graphite India was applied for the proposition that a mere intimation of the proposal to adjust is an idle formality and that adjusting more than 20 per cent while disregarding the Office Memoranda is bad in law; Danieli India and Gaurav Enterprises were noted to the same effect; Sun Pharmaceutical was cited for the unfairness of unbridled adjustment. Northern Coal Fields was distinguished as a case where a conditional stay had been granted and had expired, and its observation that mere service of intimation suffices was held not to be in consonance with the settled position or with Instruction No. 12/2013; the Supreme Court's dismissal of the SLP in that case was read as an order 'in the facts of' the case. Mohan Wahi, Chemester Food and Gouri Sankar Awasthi were each distinguished on their facts. On the assessee's own authority the Court parted company with Rajendra Kumar: if filing an appeal by itself meant the assessee was not in default, section 220(6) would have nothing to operate on and no deposit of any percentage would ever be required, and Golam Momen holds that the scope of making an application is implicit in the section. Finally the Court refused the Revenue's argument that failure to contest the demand on the portal dashboard forfeited the right to object, holding that adjustments under section 143(1) and under section 245 operate in distinct fields at distinct stages and that a section 245 notice is a fresh statutory trigger overriding the dashboard status. In the words reproduced by the source cited on this page: "It is evident from records that prior intimation under Section 245 of the 1961 Act was given on November 10, 2023 allowing the assessee 21 days to respond thereto, but the refunds were adjusted on the following day itself. This constitutes a clear breach of the authority to adjust in terms of the aforementioned provision." The decision followed or applied Graphite India Ltd v. DCIT (Calcutta High Court) — followed; Danieli India Ltd v. ACIT (Calcutta High Court, unreported) — followed; Gaurav Enterprises v. Union of India (Calcutta High Court, unreported) — followed; State of Madhya Pradesh v. Bhailal Bhai — applied on delay; Rajendra Kumar v. ACIT, [2022] 445 ITR 622 (Raj) — respectfully disagreed with (para 34), to the limited extent that filing an appeal in time means the assessee is not in default; Northern Coal Fields Ltd v. ACIT (Madhya Pradesh High Court) — distinguished (para 42); Aluminium Corporation of India Ltd v. C. Balakrishnan — followed on the judicial exercise of discretion.
It was decided by the High Court on 2026-05-04 and is reported as WPO 780 of 2025; 2026:CHC-OS:153 (Calcutta High Court, Original Side). Binding within that High Court's jurisdiction. Persuasive elsewhere. A High Court decision binds the assessing officer, the Commissioner (Appeals) and the Income Tax Appellate Tribunal within that state, and is persuasive elsewhere. If your assessment is in a different jurisdiction, check whether your own High Court has taken the same view before relying on it. On section 245, section 220(6), section 143(1), section 246A, the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. The writ petition was disposed of. The challenge to the adjustment of 25 October 2022 was not entertained, the writ petition having been filed more than three years afterwards with no explanation, that being the period within which a suit for the money would have had to be brought (para 12). The challenge to the adjustment of 11 November 2023 was entertained despite a two-year delay, because no third-party right had accrued, there was no waiver, and the adjustment was in any case subject to the pending appeal (para 13). On the merits, section 245 does not exclude natural justice, so the Revenue must issue an intimation, examine the objections and then decide whether to adjust (para 22); giving 21 days and adjusting on the following day was a clear breach of the authority to adjust (para 25) and foreclosed the right of objection that would have invoked the Assessing Officer's discretion under section 220(6) (para 26). Where no section 220(6) application has been made the Assessing Officer is justified in proceeding to adjust, but the adjustment must conform to section 245 (para 24), and in exercising the power he must keep in mind the Instruction of 2 February 1993 and the Office Memoranda of 29 February 2016, 31 July 2017 and 25 August 2017 (paras 27 and 35). The Court respectfully disagreed with Rajendra Kumar to the limited extent that it held an assessee not to be in default merely on filing an appeal in time (para 34). The Revenue was directed to refund the amounts adjusted in excess of 20 per cent of the disputed demand for AY 2018-19 pursuant to the November 2023 intimation within eight weeks, excluding from that computation the amounts adjusted on 25 October 2022, and the petitioner was held not entitled to any interest on the sum refunded because of its two-year delay (para 47). The Commissioner (Appeals) was requested to decide the appeal within two months, and the refund direction was made subject to that decision (para 48). No costs. It arises in Refunds, Interest & Condonation, Demand, Recovery & Stay and Appeals matters, on section 245, section 220(6), section 143(1), section 246A of the Income Tax Act 1961, and was decided by Om Narayan Rai J. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. File a section 220(6) application asking not to be treated in default, and do not rely on the mere filing of the appeal; this Court expressly held that filing an appeal is not a stay and disagreed with Rajendra Kumar on that point. Move within months, not years. Compute the three-year civil limitation period from the date of each adjustment: an adjustment older than that was left undisturbed here, and even a two-year delay cost the assessee all interest on the money recovered. Frame the prayer as a refund of the amount adjusted in excess of 20 per cent of the disputed demand for the specific year, identifying each intimation separately, because the Court granted relief on one intimation and refused it on the other. If the Department says you should have contested the demand on the portal's outstanding demand dashboard, answer with paragraphs 38 and 39 — the section 245 notice is a fresh statutory trigger that overrides the dashboard status. Ask, as this petitioner did, for a direction to the Commissioner (Appeals) to decide the appeal within a fixed time; the Court gave two months, and the refund direction was made subject to that decision.
High Courts differ on this point. This judgment expressly disagrees with a Division Bench of another High Court on a point that matters to every assessee facing a refund adjustment while an appeal is pending, and no Supreme Court decision resolves it. The judgment was read. At para 32 the Calcutta High Court set out the Rajasthan High Court's observation in Rajendra Kumar v ACIT that 'Nowhere in the provisions of Section 220(6) of the Income Tax Act, it is specified that the stay application has to be filed. The mandate of Section 220(6) of the Income Tax Act makes it very clear that once an appeal is filed within the time in the prescribed format, the assessee will not be deemed as an assessee-in-default.' At para 34 it held: 'this Court respectfully disagrees with the observations made in Rajendra Kumar (supra) to the limited extent that once an appeal is filed within the time in the prescribed format, the assessee will not be deemed as an assessee-in-default'. On the Calcutta view the assessee must affirmatively seek a stay or object to the s.245 intimation to obtain protection. On the substantive relief the Court held that adjusting the refund one day after issuing a 21-day s.245 intimation was a clear breach and directed refund of everything taken beyond 20 per cent of the disputed demand, but declined interest on it. Both searches returned no later treatment of this judgment itself; the citedby index is empty and a name search returns only earlier orders in the same WPO 780 of 2025. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
Read from the indiankanoon print view in four passes. Paragraphs 16 to 21, which set out the text of sections 220 and 245 and the natural justice discussion, could not be reproduced: the retrieval layer refused them as too long, so the reasoning attributed to that stretch is taken from paragraph 22, which was reproduced in full. Paragraphs 12 and 14 came back with quotation marks around clauses that appear to have been added by the retrieval layer, and paragraph 14 as returned reads 'once an was appeal had been preferred', which is plainly corrupted; neither has been quoted. The tail of paragraph 25 was separately confirmed by exact-phrase retrieval on indiankanoon, which also returned the neutral citation 2026:CHC-OS:153. Note the internal date inconsistency in the report: paragraph 2(f) and paragraph 47 refer to the intimation as dated 10 November 2023 with adjustment on 11 November 2023, while the Revenue's submission at paragraph 4(j) says the adjustment was made on 13 November 2023, and paragraph 47 refers to 'the intimation dated November 11, 2023'. Nothing in the reasoning turns on the one-day difference. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The writ petition was disposed of. The challenge to the adjustment of 25 October 2022 was not entertained, the writ petition having been filed more than three years afterwards with no explanation, that being the period within which a suit for the money would have had to be brought (para 12). The challenge to the adjustment of 11 November 2023 was entertained despite a two-year delay, because no third-party right had accrued, there was no waiver, and the adjustment was in any case subject to the pending appeal (para 13). On the merits, section 245 does not exclude natural justice, so the Revenue must issue an intimation, examine the objections and then decide whether to adjust (para 22); giving 21 days and adjusting on the following day was a clear breach of the authority to adjust (para 25) and foreclosed the right of objection that would have invoked the Assessing Officer's discretion under section 220(6) (para 26). Where no section 220(6) application has been made the Assessing Officer is justified in proceeding to adjust, but the adjustment must conform to section 245 (para 24), and in exercising the power he must keep in mind the Instruction of 2 February 1993 and the Office Memoranda of 29 February 2016, 31 July 2017 and 25 August 2017 (paras 27 and 35). The Court respectfully disagreed with Rajendra Kumar to the limited extent that it held an assessee not to be in default merely on filing an appeal in time (para 34). The Revenue was directed to refund the amounts adjusted in excess of 20 per cent of the disputed demand for AY 2018-19 pursuant to the November 2023 intimation within eight weeks, excluding from that computation the amounts adjusted on 25 October 2022, and the petitioner was held not entitled to any interest on the sum refunded because of its two-year delay (para 47). The Commissioner (Appeals) was requested to decide the appeal within two months, and the refund direction was made subject to that decision (para 48). No costs.
TaxSphere, “P. S. Srijan Height Developers v ACIT”, https://taxnotice.vittsphere.com/caselaw/case/ps-srijan-height-developers-245-adjustment-before-the-reply-period-expired/ (validity last checked 2026-09-07)
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The CPC has adjusted my entire refund against a demand that is under appeal. Do I have to file a separate stay application before I can complain?
My refund was simply taken against another year's demand and I was never told. Does the notice have to come first?
Your refund was adjusted against an old demand. Did they have to tell you first?
Your refund was adjusted against demands that were already stayed. Is that lawful?
