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. Your Lordships may be pleased to admit this petition;

B. Your Lordships may be pleased to allow this petition;

C. Your Lordships may be pleased to issue a writ of Mandamus or any other appropriate writ, order or direction holding the action of non-grant of refund of the amount collected without raising formal demand thereof by passing an order as illegal and arbitrary and Your Lordships may direct the Respondent No.3 to immediately pay refund of Rs.14,61,850/- along with interest at commercial rate for the period from the date it was recovered from the petitioner uptil the date on which the said amount is paid to the petitioner."

(2.)The writ applicant No.1 is a partnership firm and the writ applicant No.2 is one of the partners of the said firm.
(3.)The writ applicants seek to challenge the decision of the respondent No.4 in declining to grant the refund of the amount recovered during the search for the period between F.Y. 2012-13 and 2015-16 to the tune of Rs.14,61,850/-, which according to learned counsel for the writ applicants has not been appropriated by passing the audit assessment orders and the same now having become time barred.