As per amendment made in section 115A now in the case of non- resident taxpayer, where the total income includes any income by way of royalty and fees for technical services (FTS) received by such non- resident from govt. or any Indian company will deduct 10 % TDS instead of 25 %.
Sir my question :- Since non- resident don’t have PAN of Indian then section 206AA will be applicable so 20% TDS will be deduct. So as per my understanding, in any case 20% TDS will be deduct that means this provision is not so beneficial for NR.
Amendment to Section 115A reduces TDS on non-resident royalties, but Section 206AA's PAN requirement complicates benefits. A discussion on a forum addressed the tax deduction at source (TDS) on royalty and fees for technical services for non-resident taxpayers. An amendment to Section 115A reduced TDS from 25% to 10% for non-residents without a Permanent Account Number (PAN) in India. However, Section 206AA mandates a 20% TDS if the non-resident lacks a PAN, rendering the amendment less beneficial. A respondent agreed, noting that Indian entities often have to bear the additional TDS cost due to limited negotiating power with foreign service vendors. (AI Summary)
TaxTMI 
TaxTMI 
