Dismissing the review petition of the Revenue the Court held that  at the time of disposal of the writ petition, the counsel for review applicant Revenue had not disputed that the issue raised in the present writ action stands covered by the judgment in the case of Sanjay Sudan v. ACIT  (2023) 331 CTR  797/  224 DTR 99(Delhi) (HC). Now, counsel for the review applicant contended that the case which led to the judgment of Sanjay Sudan stood on different footing insofar as in the said case, the assessee had produced Form No. 16A to establish the tax deducted at source. However, Form 16A is not the only piece of evidence in that regard. Assessee can rely on other material.. From the language of S. 205, it is clear that the bar operates as soon as it is established that the tax had been deducted at source and it is wholly irrelevant as to whether the tax deducted at source is deposited or not and whether Form No. 16A has been issued or not. There is no error, much less an error apparent on the face of record which would persuade the Court to engage in reviewing the impugned order dt. 31st May, 2023.  Revenue cannot recover the deficit tax at source from the assessee, which was deducted and pocketed by CAL, and they cannot also refuse to grant credit for the same.  What the Revenue cannot do directly, it is impermissible for it to reach the same end indirectly. Revenue  is directed to  refund Rs. 11,39,870 to the assessee. Followed Sanjay Sudan v. ACIT  (2023) 331 CTR 797 / 224 DTR 9(Delhi) (HC). (AY. 2011-12)