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2016 (12) TMI 1610 - DELHI HIGH COURTValidity of attachment orders u/s 281B - seeking release of amount pursuant to the SBLCs - confirmation of tax liability of non-resident (FOWC) having PE in India - Held that:- The Court is of the opinion that in the light of the judgment delivered in Formula One World Championship Limited, Jaiprakash Associates Ltd. Versus CIT, International Taxation-3 & Anr. [2016 (12) TMI 123 - DELHI HIGH COURT] the order impugned and the attachment appear to be prima facie warranted in law. In the light of this order, the Court is of the opinion that the petitioner’s bank is obliged to honour the direction of attachment by the Revenue and not to release any amount pursuant to the SBLCs as well as any consequential instruments and acts which would effectuate the commitments there under pending crystallization of the actual amounts by the revenue, till further orders. Directed accordingly. Counsel for the revenue states that the actual amounts would be indicated in an appropriate consequential order within two weeks under Section 195 of the Income Tax Act, 1961 and till further orders in these proceedings.
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