In cases where the assessee claims refund and the one year period is over, the Revenue cannot be inactive and the Assessing Officer must apply his mind to consider whether the facts and circumstances of the case warrant the refund. It is an unjust and arbitrary approach to withhold refunds in anticipation of additions or disallowances that may be made after completion of assessment proceedings. The Court held that   the Revenue was unable to demonstrate any cogent reasoning for withholding the refunds, except for arguing that since the regular assessment was pending, the Department was not obliged to issue the refund. The Assessing Officer was to process the returns and pass consequential order. ( AY.2016-17, 2017-18, 2018-19)