quashed the adjustment order and directed refund of Rs. 17,10,15,285/- for the 4th quarter of 2015-16 and Rs. 5,44,39,148/- for the 1st quarter of 2017-18, along with interest as per Section 42 till the date of realisation.2 In respect of the default notices, the High Court gave liberty to the respondent to avail statutory appeal under Section 74 of the Act. 2 WP (C) 2491/2023, judgment dated 21.09.2023 (‘Impugned judgment’). 24. The present appeal is restricted to the issue of quashing the adjustment order. The High Court placed reliance on the Delhi High Court’s judgment in Flipkart India Private Limited v. Value Added Tax Officer, Ward 3003 to summarise the law on refund under Section 38. It held that the department must scrupulously adhere to the time limit for processing and issuing the refunds under Section 38. Whenever the department seeks to obtain necessary information under Section 59 of the Act, it must take steps within the time limit envisaged under the Act. Further, the