Where an assessment order resulted in a refund to the assessee and a moratorium under section 14 of the Insolvency and Bankruptcy Code, 2016 was subsequently declared, the High Court held that the revenue must release the entire refund amount without making any adjustment against past pending demands. The Court clarified that the revenue’s remedy is to lodge its claim with the liquidator. However, the Court also ruled that amounts of tax deducted at source (TDS) collected by the revenue prior to the commencement of the moratorium are treated as ‘tax paid’ under section 199 of the Income-tax Act, 1961, and do not constitute an ‘asset’ of the corporate debtor. Consequently, the revenue cannot be directed to refund such pre-moratorium tax payments. (AYs. 2014-15 to 2016-17)