The assessee’s applications for refund of excess TDS deposited u/s 195 for AYs 2010-11 to 2012-13 were rejected by the Commissioner relying on para 9 of CBDT Circular No. 7/2007 dated 23-10-2007, which restricted the time period. The Delhi High Court held that neither S. 237 nor S.  239 prescribe limitation for refund claims, and the earlier sub-S. (2) of S.  239 prescribing timelines had been omitted by Finance Act 2019. CBDT’s power under S.  119 is only to relax statutory provisions, not to curtail rights or extinguish claims. Para 9 of the Circular was therefore held ultra vires and beyond CBDT’s powers. The rejection order was quashed and refunds directed to be granted. (AY. 2010-11 to 2012-13)