Section 241A of the income tax Act, 1961 — Refund — Exercise of the powers under section 241A was not justified in facts of the case as auto generated communication which contained the note of withholding of the refund in terms of section 241A does not satisfy any of the legal tests for passing  said order ; further merely because in the immediately preceding year, the assesse had declared a positive income as against substantial loss declared in the present assessment year, that by itself cannot be a ground to doubt the contents of the return or the claim of the assessee with respect to the loss suffered; the reference to the several issues which are common the present assessment year and which are pending before the Tribunal also in facts of the case would not be a ground to withhold the refund — Vodafone Idea Ltd vs. Deputy Commissioner of Income tax [2019] 311 CTR (Bombay) 385