https://www.taxtmi.com/caselaws?id=212074 Retrospective Explanation 2 to section 10(15)(iv)(c) treated usance interest paid outside India by a ship-breaking undertaking on purchase of ships from abroad as interest on foreign borrowing, excluding it from total income. Because the reassessment notice under section 148 rested on the premise that such interest was taxable and that section 40(a)(i) had not been complied with, the statutory amendment removed the very foundation for reopening. The Gujarat HC therefore quashed the reassessment notice as unsustainable. en-us Thu, 17 Mar 2011 00:00:00 +0530 Fri, 13 Apr 2012 08:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212074 Retrospective Explanation 2 to section 10(15)(iv)(c) treated usance interest paid outside India by a ship-breaking undertaking on purchase of ships from abroad as interest on foreign borrowing, excluding it from total income. Because the reassessment notice under section 148 rested on the premise that such interest was taxable and that section 40(a)(i) had not been complied with, the statutory amendment removed the very foundation for reopening. The Gujarat HC therefore quashed the reassessment notice as unsustainable. Case-Laws Income Tax Thu, 17 Mar 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212074