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Bank-account freezing under anti-money-laundering law requires recorded reasons; writ review remains available despite an alternative statutory remedy...
Additional legal grounds raising pure questions of law may be admitted for the first time on appeal where all material facts are on record and no further inquiry is required. Rectification of a consequential assessment order must be confined to the mistake identified in the rectification notice and must arise from that order itself. Interest under section 234B, having merged with the appellate order, could not be rectified in the consequential order; any section 234C omission lay in the original assessment. Further, a debatable advance-tax interest levy under the statutory proviso is not a mistake apparent from record. The rectification and its appellate confirmation were invalid.
Additional legal grounds raising pure questions of law may be admitted for the first time on appeal where all material facts are on record and no further inquiry is required. Rectification of a consequential assessment order must be confined to the mistake identified in the rectification notice and must arise from that order itself. Interest under section 234B, having merged with the appellate order, could not be rectified in the consequential order; any section 234C omission lay in the original assessment. Further, a debatable advance-tax interest levy under the statutory proviso is not a mistake apparent from record. The rectification and its appellate confirmation were invalid.
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TaxTMI 
TaxTMI 
of 4927 
