JUDGMENT :

J.B.PARDIWALA, J.

1. By this writ application under Article 226 of the Constitution of India, the writ applicants have prayed for the following reliefs;

“(A) Quash and set aside the order dated 12.07.2019 passed by Respondent No.1 at Annexure-A to the extent it does not issue refund to the Petitioner No.1 but adjusts against the demand of A.Y.2012-13.

(B) Direct the Respondent No.1 to issue refund to the Petitioner No.1 arising out of the order giving effect of the order of CIT(A) for A.Y.2014-15;

(C) Quash and set aside the order dated 12.07.2019 passed by Respondent No.2 at Annexure- A to the extent it puts a condition of adjustment of future refunds arising to the Petitioner without any limit and to direct the Respondent No.2 to grant unconditional stay of demand against the application filed by the Petitioner dated 10.07.2019 till the disposal of appeal by the Income Tax Appellate Tribunal.

(D) Prohibit the Respondent No.1 to recover any amount from the Petitioner No.1 towards the demand raised for AY 2012-13 or 2010-11 or adjust any refunds arising to the petitioner No.1 a