Allowing the petition the Court held that, here was no allegation that the tax was not being paid or that there was any irregularity in filing the returns. From the order and the record, it was evident that there was no reason recorded for coming to the conclusion that grant of refund was likely to adversely affect the Revenue.  Mere pendency of the proceedings under S.  143(2) in itself is not enough to withhold the refund  .The order was unsustainable.( AY.2017-18, 2018-19)