52. Power to withhold refund in certain cases.-

(1) Where an order giving rise to refund is the subject matter of an appeal or further proceeding or where any other proceeding under the Act is pending and the Commissioner is of the opinion that the grant of such refund is likely to adversely affect the revenue and that it may not be possible to recover the amount later, the Commissioner may, withhold the refund till such time as he may determine.

(2) Where a refund is withheld under sub- section (1), the dealer shall be entitled to interest as provided under sub-section (1) of section 51 if as a result of the appeal or further proceeding or any other proceeding he becomes entitled to the refund.