The Revenue adjusted refunds due to the assessee for AYs 2017-18 and 2022-23 against a disputed demand for AY 2018-19. This adjustment was made without issuing the mandatory prior intimation in writing as required under section 245, and while the assessee’s applications for stay of the demand were pending. The High Court held that the power to set off a refund can be exercised only after giving a prior written intimation of the proposed action to the assessee. This requirement is mandatory, not discretionary. An adjustment made in breach of this statutory pre-condition is illegal and contrary to law. Consequently, the Court set aside the adjustments and directed the Revenue to issue the refunds due to the assessee. (AY. 2017-18, 2018-19,  2022-23)