Tribunal held that  for failure to deduct tax at source in respect of interest paid to resident no disallowance can be made  as the  recipient of income, has taken into account amount received from payer in computing income as declared in return and has paid due tax on returned income. Second proviso to section 40(a)(ia) inserted by Finance (No. 2) Act, 2004, with effect from 1-4-2005 is curative and has retrospective effect Section 40(a)(ia), read with section 201, of the Act. (AY. 2006 -07)