https://www.taxtmi.com/caselaws?id=208402 Retrospective Explanation 2 to section 10(15)(iv)(c) was treated as removing the very basis for reassessment where reopening under section 148 rested on proposed disallowance of usance interest paid to non-residents on ship purchases. The explanation deems such usance interest, in the specified ship-related context, as interest on a foreign debt incurred for purchase outside India, with the result that it could not be included in total income on the footing assumed by the reopening. The Gujarat HC article notes that once the statutory clarification nullified the alleged escapement, the reassessment notice could not survive and was quashed in favour of the assessee. en-us Thu, 17 Mar 2011 00:00:00 +0530 Wed, 19 Dec 2012 14:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208402 Retrospective Explanation 2 to section 10(15)(iv)(c) was treated as removing the very basis for reassessment where reopening under section 148 rested on proposed disallowance of usance interest paid to non-residents on ship purchases. The explanation deems such usance interest, in the specified ship-related context, as interest on a foreign debt incurred for purchase outside India, with the result that it could not be included in total income on the footing assumed by the reopening. The Gujarat HC article notes that once the statutory clarification nullified the alleged escapement, the reassessment notice could not survive and was quashed in favour of the assessee. Case-Laws Income Tax Thu, 17 Mar 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208402