On writ the Court held that the refunds had been adjusted against outstanding tax demands by the Assessing Officer without mentioning that the assessee fell in the category mentioned in paragraph 4(B) of the office memorandum dated February 29, 2016. Without any order under section 245 having been passed the assessee was entitled to refund of adjustments made in excess of 20 per cent. of the disputed tax demands for the assessment year 2016-17. The restrictive stay order dated February 11, 2019 issued by the Assistant Commissioner granting stay to the assessee only till December 31, 2019 was in violation of the directions of the Central Board of Direct Taxes and earlier orders of court wherein it had been held that the Assessing Officer must grant stay till the disposal of the appeal before the Commissioner (Appeals). (AY.2016-17)