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The Tribunal clarified that refundable income tax can be applied against outstanding super tax liability under Section 4C of the Income Tax Ordinance, 2001, as mandated by Section 170(3)(a).🔹 Authorities below had rejected adjustment by relying on M/s CM Pak Limited v. Federation of Pakistan, which dealt with withholding tax credits not with refund appropriation.🔹 The Tribunal distinguished between credit in computation and appropriation of refund against demand, holding that once excess tax is established, the Commissioner must apply it in reduction of “any other tax due” under the Ordinance, including super tax.🔹 It emphasized that recovery provisions (Sections 138 & 140) cannot override Section 170(3), and Rule 210B requires satisfaction that no refund is available befo...