Order refusing to issue refund is not appeallable u/s 246A but is subject to revision u/s 264

Aditya Marine Limited Vs DCIT (International Taxation) (Bombay High Court)

A revision would lie to the Commissioner of Income Tax from any order passed by the authority subordinate to him in respect of any proceeding under the Act. In the present case, the order has been passed by the officer subordinate to the Commissioner of Income Tax and the same has been passed in respect of proceeding initiated by the Petitioner seeking refund. The impugned order dated 9 April 2019 adjudicates a lis between the Revenue and the Petition

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