On writ the High Court held that after omission of s. 239(2) w.e.f. 1-9-2019, the Act does not prescribe any limitation for claiming refund under ss. 237/239 in such cases, and therefore para 9 of CBDT Circular No. 7 of 2007 fixing a two-year period for refund of excess TDS was beyond the power conferred under s. 119 and could not extinguish the assessee’s substantive right to seek refund. Accordingly, rejection of the assessee’s refund claim as time-barred was held unsustainable. The Court further held that interest/premium paid on FCCBs and ECBs utilised for funding overseas subsidiary operations was for purposes of earning income from a source outside India and fell within s. 9(1)(v)(b); hence no tax was deductible at source u/s. 195, and the excess tax deposited was refundable.  Taxing statutes are interpreted by following the principles of strict interpretation. While interpreting a taxing statute, there is no room for any intendment.    (AY. 2011-12 to 2013-14)