The provisional attachments and recovery orders were subsequently revoked by the authorities, with the petitioner required to retain refunded amounts and sale proceeds in its account, maintaining a minimum balance of ₹221 crores.

The tribunal noted that the CIT(A) had not verified whether the service tax was actually received or routed through accounts and had not obtained a remand report from the AO

The Division Bench held that once the earlier Bench had remitted the matter for merits without entertaining the plea of alternative remedy