CPC data, appears that the Petition has in fact, been issued Form 5 under the Direct Tax Vivad se Vishwas Act, 2020. It also emerges that the system continues to display certain legacy demands for AYs 2013-14, 201415 and 2015-16 and that refunds for other assessment years, at various points in time, been adjusted u/s 245 against these demands. Further, rectification applications and stay application filed by the Petitioner for AY 2017-18 and 2018-19 are found to be pending disposal. In view of the above, the matter involves multiple assessment years, past rectification orders, Vivad se Vishwas Form Farm 5, several adjustments made by CPC u/s 245, and pending rectification stay applications. A comprehensive reconciliation is required between the jurisdictional records and CPC systems to (i) verify the exact outstanding lawful demand, if any, for each year. (it) correct any erroneous or non-existent demands still reflected on the portal and (iii) take a considered decision regarding release of refund and interest in accordance with the Act and CBDT instructions. This exercise is already being taken up but will reasonably require some further time, including coordination with CPC. You may kindly request Hon’ble Court to grant the Department a further period of 12 weeks to complete the reconciliation and dispose of pending rectification /stay applications. It may be submitted that the Department is acting bona fide, there is no intention to withhold any lawful refund, and that the short adjournment sought is only to ensure that the correct legal position and reconciled figures are placed before the Hon'ble Court so that the writ petition can be addressed in a fair and effective manner.
