Tribunal remanded the matter to the Assessing Officer. CIT(Judicial) had received the order of the Tribunal on 31st Jan., 2019. Order was passed on 13th Feb., 2023 by adjusting the refund. On writ the Court held that the  Respondents have failed to address any submission which may compel the Court to doubt the prima facie opinion that came to be recorded on earlier occasion that period of limitation is liable to be computed from the date when the order is received by the concerned statutory authority. Contention that the period of limitation being liable to be computed as commencing from the date when the SLP was dismissed by the Supreme Court and consequently from 29th Oct., 2020 is not sustainable. Further, the Court also observed that they have  unable to either sustain or countenance the claim of the respondents that the order dt. 30th Jan., 2021 of the TPO was either not communicated to them or was not in their knowledge. That stand clearly appears to be wholly incorrect and factually untenable. Even if the benefits of TOLA were extended to the respondents, undisputedly, the order of assessment was liable to be framed lastly by 30th Sept., 2021 whereas the order was passed on 13th Feb., 2023. Accordingly the order is  set aside. Adjustment of earlier years refund against perceived demand was not sustainable. Accordingly the  Respondents are directed to re-compute the refund payable to the assessee along with statutory interest.  (AY.  2011-12)