( 1 ) THIS group of 32 matters has been argued together having regard to the nature of controversy and the common questions of law involved, which are as under : I. QUESTIONS OF LAW INVOLVED IN THESE APPEALS: 1. In Tax Appeal No. 273/2002:-[1] Whether the usance interest paid by the assessee apart from the purchase price of the ship would fall within the scope of definition of term `interest u/s. 2[28a] of the Income Tax Act, 1961?[2] Whether the Appellate Tribunal was right in law and on facts in deleting the disallowance under section 40[a][i] of the Act for the failure on the part of the assessee to deduct tax at source from usance interest paid to a non-resident under section 195[1] of the Act?[3] Whether the Appellate Tribunal was right in law and on facts in holding that usance interest partakes the character of purchase price and therefore not liable to deduction at source u/s 195[1] of the Act?[4] Whether the Appellate Tribunal was right in law and on facts in allowing the deduction u/s 80hh and 80i to the assessee holding that ship breaking activity gives rise to manufacture and production of altogether a new article or thing?in Tax Appeal Nos. 285, 28