Excess Income Tax Refund Set-Off Against Disputed Penalty Impermissible: Bombay HC

Fork Media Group Private Limited Vs Centralized Processing Centre (Bombay High Court)

The writ petition challenged an order dated 19 December 2024 passed by the Centralized Processing Centre (CPC) adjusting tax refunds against a disputed penalty without granting refund of the excess amount. The petitioner contended that refunds of ₹37,00,594 for AY 2022–23 and ₹43,17,534 for AY 2023–24 were adjusted against a penalty demand of ₹1,16,85,263 levied under section 270A for AY 2021–22, even though the penalty was under appeal before the First Appellate Authority. As a result

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