During the year, the department made an adjustment of refund due to the assessee for assessment year 2014-15 against alleged demand for assessment year 2016-17. On writ, the Court held that the assessee had made payment of 20 per cent of the demand for assessment year 2016-17, and appeal for the said assessment year was pending as of today. Since the appeal for assessment year 2016-17 was pending and the assessee had made payment of 20 per cent of the demand, adjustment of refund for assessment year 2014-15 against the demand for assessment year 2016-17 was not justified. (AY. 2014-15, 2016-17)