2008 (10) TMI 6 - SUPREME COURT

Usance interest paid for purchase of the vessel for ship breaking – contention of the assessee that such interest partook of the character of the purchase price and, therefore, TDS was not deductible u/s 195(1), is acceptable - Since tax was not assessable in India, there was no question of TDS being deducted by the assessee - Tribunal was right in allowing the deduction u/s 80HH & 80I holding that the ship breaking activity gave rise to the production of a distinct & different article