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New Delhi · Saturday, 07 November 2026
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Supreme Court of India 2017-08-25 partly_allowed

Royal Bank of Scotland Plc vs Axis Bank Limited & Ors

Bench: 2 — A.K. Sikri

In Brief

The Supreme Court upheld the Income Tax Department's provisional attachment order under Section 281B of the Income Tax Act issued against Letters of Credit (LCs) opened in favour of Formula One World Championship Limited (FOWC). FOWC had received income in India for conducting Formula One races and, following a High Court judgment establishing its tax liability, invoked the LCs to receive funds despite being informed of the attachment order. The Court held the attachment valid and enforceable, but directed FOWC to deposit 15.45 million USD received under the LCs with the Bombay High Court, with the amount released to confirming banks only after FOWC's deposit, thereby balancing tax protection and banking obligations.

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Income Tax Law Provisional Attachment International Banking Letters of Credit Tax Liability Permanent Establishment

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