Assessment for assessment years 1998-99 to 2002-03 had been made resulting in demand of Rs. 67.73 lakhs for all five years. An appeal was preferred against said assessment orders before Commissioner (Appeals) and same was pending consideration. Matter had been heard and orders were reserved and awaiting pronouncement. In meanwhile, refund was due to assessee pursuant to assessment made for assessment year 2021-22 to extent of Rs. 1.92 crores. The assessee filed  petition praying for issuance of Writ of Mandamus forbearing Commissioner (Appeals) from taking any coercive steps to recover/set off refund due towards liability for other assessment years-Revenue submitted that it had already set out/adjusted refund for some years, although exact numbers were not available. Court held that if  the assessee intended to seek protection against any coercive proceedings, it would  be open to assesseee to approach appropriate authority under section 220(6) by filing stay application pending appeal. (AY. 1998-99 to 2002-03)