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    <title>2026 (3) TMI 1576 - DELHI HIGH COURT</title>
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    <description>Dividend repatriation to foreign shareholders was permitted despite pending tax demands because accumulated dividend could not be withheld indefinitely when the assessments were under challenge and the restraint orders were not meant to continue without balance. The Court required tax deduction at source and equivalent security by way of an auto-renewable, interest-bearing fixed deposit receipt in a nationalised bank, thereby protecting the Department while allowing remittance. The income-tax refund for the relevant year was also permitted to be adjusted against the outstanding demand, and the lien on the existing fixed deposit receipts was lifted, leaving the company free to withdraw them if desired.</description>
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    <pubDate>Wed, 18 Mar 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=788821</link>
      <description>Dividend repatriation to foreign shareholders was permitted despite pending tax demands because accumulated dividend could not be withheld indefinitely when the assessments were under challenge and the restraint orders were not meant to continue without balance. The Court required tax deduction at source and equivalent security by way of an auto-renewable, interest-bearing fixed deposit receipt in a nationalised bank, thereby protecting the Department while allowing remittance. The income-tax refund for the relevant year was also permitted to be adjusted against the outstanding demand, and the lien on the existing fixed deposit receipts was lifted, leaving the company free to withdraw them if desired.</description>
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