S. Muralidhar, J.

1. The challenge in this writ petition by Tata Teleservices Ltd. is to an Instruction No. 1 of 2015 dated 13th January 2015 issued by the Central Board of Direct Taxes (“CBDT”) (Respondent No.1) and the consequential letter dated 8th September 2015 issued by the Deputy Commissioner of Income Tax (“DCIT”) Circle 25(1) (“Respondent No.2”) denying refund of the Petitioner under Section 143(1) of the Act for three assessment years (AYs) 2012-13, 2013-14 and 2014-15. The refunds were declined for the reason that the case was pending scrutiny and that in the light of Section 143(ID) of the Income Tax Act, 1961 (“Act”) and the Instructions of the CBDT, refund could not be processed for the said AYs.

2. The facts in brief are that the Petitioner is engaged in the business of providing telecom services. It is stated that the Petitioner has over the years accumulated losses in excess of Rs. 31,000 crores. As such in the returns of income filed for the AYs 2012-13 to 2015-16, the Petitioner claimed refund. A tabular depiction of the losses and the corresponding clai