Held that a non-resident company purchased shares of another non-resident company having assets in India, it could not be said to have defaulted in not withholding taxes from payments made to non-resident, as, while transaction for purchase of shares in question took place on 11-7-2008, Explanation 2 to section 195 which imposes tax withholding obligations on non-residents in respect of payments involving income taxable in India, was introduced by Finance Act, 2012. (AY. 2009 10)