The petitioner, an individual, filed his return of income for AY 2015-16 on 28 September 2015, declaring Rs. 56,65,660 as income. The return was selected for scrutiny, and an assessment order under Section 143(3) was passed on 20 December 2017, assessing the income at Rs. 1,11,85,520, leading to a demand of Rs. 37,91,550. The petitioner voluntarily deposited 20% of the demand, which was Rs. 7,58,310, before filing a stay application on 29 January 2018. However, the stay application remained undecided for more than six years. Meanwhile, an intimation under Section 143(1) was issued on 6 October 2022, adjusting the refund of Rs. 6,05,030 for AY 2022-23 against the demand for AY 2015-16. The stay application was finally decided on 17 April 2024, where the AO granted a stay for the balance amount which is Rs. 30,33,240, acknowledging that 20% had already been paid. The petitioner filed a writ petition challenging the adjustment of refund, arguing that he had already complied with the 20% payment requirement, and the refund adjustment was unlawful. The court held that the delay of six years in deciding the stay application was unjustified and that respondents cannot take advantage of their own delay. The court directed the revenue to refund Rs. 6,05,030 within four weeks and suggested that the petitioner apply for an early hearing before CIT(A). The court further directed CIT(A) to dispose of the appeal before 31 May 2025 and ordered Respondent No. 5 to investigate the delay in disposing of the appeal pending since 2018. [WP. No. 13185/2024, dt. 24.02.2025,( AY. 2015-16)