Whether refunds in excess of 20% of demand pending appeal can be withheld/adjusted? High handedness of department -Rs 50000/- cost imposed

Rajendra Kumar Vs ACIT (Rajasthan High Court) Sub-Whether refunds in excess of 20% of demand pending appeal can be withheld/adjusted? High handedness of department -Rs 50000/- cost imposed. The Division bench of Rajasthan High Court in this case was dealing with a matter where refund for AY 2018-19 was determined and upon notice u/s 245 having been received, the appellant requested adjusted of 20% of the demand for AY 2017-18 for which year appeal was pending and requested refund of the balance amount. However, inspite of the said request, the entire refund was adjusted and the matter was chal...