Bank-account freezing under anti-money-laundering law requires recorded reasons; writ review remains available despite an alternative statutory remedy...
Appellate jurisdiction over non-transfer-pricing assessment issues covers interest-expenditure and exempt-income disallowances where no transfer-pricing adjustment or arm's-length-price determination is examined. Interest deductions require identification of interest linked to earlier and current advances and taxable interest income; where no direct nexus is established, proportional examination applies. Claims disallowed for tax-deduction-at-source non-compliance require verification of payment under the statutory proviso before determination. Exempt-income disallowance cannot exceed exempt income earned, while the Finance Act 2022 amendment operates prospectively. The additional disallowance beyond the voluntary disallowance was deleted, and the Revenue's appeal was dismissed.
Appellate jurisdiction over non-transfer-pricing assessment issues covers interest-expenditure and exempt-income disallowances where no transfer-pricing adjustment or arm's-length-price determination is examined. Interest deductions require identification of interest linked to earlier and current advances and taxable interest income; where no direct nexus is established, proportional examination applies. Claims disallowed for tax-deduction-at-source non-compliance require verification of payment under the statutory proviso before determination. Exempt-income disallowance cannot exceed exempt income earned, while the Finance Act 2022 amendment operates prospectively. The additional disallowance beyond the voluntary disallowance was deleted, and the Revenue's appeal was dismissed.
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