2024 (7) TMI 1492

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.... from repatriating royalty or dividend abroad during the pendency of the search assessment proceedings. 2. The genesis of the dispute and the facts which constrained the petitioner to approach this Court were succinctly noticed in our orders of 21 April 2022 and 30 August 2022. While disposing of the writ petition by our order of 30 August 2022, we had, apart from the stipulation referred to above, framed the following directions:- "7. Having heard the learned senior counsel for the Petitioner and the senior standing counsel for the Revenue, in view of the fact that the Petitioner has agreed to secure the Respondents, we do not wish to go into the merits of the allegations and contentions raised. Consequently, to balance the equities, wi....

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....der. (iv) The Petitioner shall not repatriate any royalty or dividend abroad. The Petitioner will be at liberty to approach this Court, in case the need so arises. (v) The Petitioner shall continue to file its monthly statement with the assessing officer of "Payments Received as well as Made". 3. Undisputedly, the respondents have failed to conclude the search assessments till date. It is also admitted before us that presently an amount of Rs. 230 crores approximately is held by the respondents This is a digitally signed order. pending finalization of those proceedings. 4. Mr. Hossain has referred to the multiplicity of issues which arise for scrutiny, the complex nature of the transactions and the sheer size of the data which is to b....