Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
HC partially lifted provisional attachment orders on bank accounts in tax liability dispute. Account in HDFC Bank Limited was completely unfrozen, while State Bank of India account received partial relief with debit restrictions lifted up to Rs. 70 Lacs. The freeze order remains effective for amounts exceeding Rs. 70 Lacs in the SBI account. Court balanced taxpayer's operational needs with revenue protection, allowing limited access to funds while maintaining security for potential tax recovery. The ruling demonstrates judicial discretion in modifying attachment orders based on proportionality and business necessity considerations.
HC partially lifted provisional attachment orders on bank accounts in tax liability dispute. Account in HDFC Bank Limited was completely unfrozen, while State Bank of India account received partial relief with debit restrictions lifted up to Rs. 70 Lacs. The freeze order remains effective for amounts exceeding Rs. 70 Lacs in the SBI account. Court balanced taxpayer's operational needs with revenue protection, allowing limited access to funds while maintaining security for potential tax recovery. The ruling demonstrates judicial discretion in modifying attachment orders based on proportionality and business necessity considerations.
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TaxTMI 
TaxTMI 
of 4891 
