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of Rate of TDS on payment to non resident - Non-availability of PAN of non resident - the ld Tax Authorities below have fallen in error in not extending the benefits of section 90(2) - The matter of fact remains that what were the rates of taxation under DTAA are not coming up from the matter before this bench therefore, the issue requires to be restored to the files of Ld. AO to take into consideration the rate of the DTAA and recalculate the tax demand - AT
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