https://www.taxtmi.com/caselaws?id=56049 Interest on a Non-resident (External) Account was held taxable because the exemption under section 10(4A) applied only to a non-resident, not to a person resident but not ordinarily resident. The distinction between "non-resident" under section 2(30) and the separate residency category under section 6(6) meant the statutory exemption ceased once the assessee was no longer non-resident. Hardship, promissory estoppel, and RBI circulars could not enlarge the clear language of the Income-tax Act, and foreign exchange instructions could not control tax liability. The later Finance Act, 1982 amendment confirmed that the earlier provision did not extend to resident but not ordinarily resident persons. en-us Mon, 19 Sep 1983 00:00:00 +0530 Wed, 01 Dec 2010 13:10:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56049 Interest on a Non-resident (External) Account was held taxable because the exemption under section 10(4A) applied only to a non-resident, not to a person resident but not ordinarily resident. The distinction between "non-resident" under section 2(30) and the separate residency category under section 6(6) meant the statutory exemption ceased once the assessee was no longer non-resident. Hardship, promissory estoppel, and RBI circulars could not enlarge the clear language of the Income-tax Act, and foreign exchange instructions could not control tax liability. The later Finance Act, 1982 amendment confirmed that the earlier provision did not extend to resident but not ordinarily resident persons. Case-Laws Income Tax Mon, 19 Sep 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56049