Royal Bank Of Scotland Plc vs Axis Bank Ltd

The Supreme Court addressed the income tax liability of Formula One World Championship Limited (FOWC) regarding income earned in India from conducting Formula One races, as contested under the Double Taxation Avoidance Agreement (DTAA) between India and the U.K. The Court upheld the provisional attachment of payments under Section 281B of the Income Tax Act, 1961, affirming the Tax Department's authority to act in such matters. The judgment clarified the applicability of tax laws in the context of international agreements and contractual obligations, reinforcing the Tax Department's position in enforcing tax liabilities.