Allowing the writ the Court held that order adjusting refund against tax dues not justified. Unconditional stay of recovery proceedings granted refunds against tax remaining payable. The order passed by respondent No. 2 was hereby set aside to the extent it put a condition of adjustment of future demands arising to the assessees. There court directed unconditional stay of the demand against the application filed by the assessee dated July 10, 2019 till the final disposal of the appeal pending before the Tribunal. (AY. 2012-13)