https://www.taxtmi.com/caselaws?id=412183 The second proviso to section 40(a)(ia) is treated as a curative provision that operates retrospectively to remove hardship where the recipient has already accounted for the interest income and paid tax on it. In that situation, the disallowance for failure to deduct tax at source should not survive. The Tribunal also accepted additional evidence showing possible tax compliance by the payees and remitted the matter for limited verification by the Assessing Officer, with directions to delete the addition if the impugned interest had already been subjected to tax in the hands of the recipients. en-us Thu, 02 Sep 2021 00:00:00 +0530 Mon, 13 Sep 2021 09:20:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412183 The second proviso to section 40(a)(ia) is treated as a curative provision that operates retrospectively to remove hardship where the recipient has already accounted for the interest income and paid tax on it. In that situation, the disallowance for failure to deduct tax at source should not survive. The Tribunal also accepted additional evidence showing possible tax compliance by the payees and remitted the matter for limited verification by the Assessing Officer, with directions to delete the addition if the impugned interest had already been subjected to tax in the hands of the recipients. Case-Laws Income Tax Thu, 02 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412183