1986 (11) TMI 136

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.... s. 10(4A) of the IT Act. This claim was denied by the Revenue on the ground that this section has been amended w.e.f. 1st April, 1982 to apply to a non-resident as denied under the Foreign Exchange Regulation Act, whereas for the present asst. yr. 1981-82, it would apply only a non-resident as defined under the IT Act and since the assessee was not an ordinarily resident during the assessment yea....

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....nt external accounts with the banks. It was submitted that since the assessee was invited to open such account with the specific assurance that the interest therefrom would be exempt, the Government could not go bank on the promise by claiming that the amendment which was made to clarify the issue was only prospective and not retrospective. In view of the well settled principle of promissory estop....