Dismissing the appeal of the assessee the Tribunal held that ; Trust formed for providing financial assistance to self-help groups. Assessee taxable as association of persons at maximum marginal rate on entire income not merely on surplus. Principle of mutuality is not applicable. However, S. 40(a)(ia) witnessed amendments inserted by the Finance Act, 2012 with effect from April 1, 2013 provided that the assessee would not deemed to be in default where the payee had taken the relevant interest income into account in computing his income, and had paid tax on the income, so returned, and to which effect the assessee furnished a certificate in the form as prescribed. Since the proviso to S. 40(a)(ia) was curative and retrospective, the assessee was entitled to the saving of the second proviso to S.40(a)(ia) . Matter was remanded. ( AY. 2009-10 )