https://www.taxtmi.com/forum/issue?id=108530 Whether Section 206AA or a Double Taxation Avoidance Agreement governs the rate of tax deduction where a non resident payee has not furnished PAN is the central issue. The facts involve payment for an electronically delivered software licence to a treaty country resident without a permanent establishment in India and without PAN. The questions concern the interaction between statutory higher withholding for non furnishing of PAN and entitlement to treaty relief, and whether any statutory obligation to gross up payments exists versus contractual allocation of tax burden. en-us Mon, 04 May 2015 16:30:38 +0530 Thu, 23 Jan 2025 15:56:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=108530 Whether Section 206AA or a Double Taxation Avoidance Agreement governs the rate of tax deduction where a non resident payee has not furnished PAN is the central issue. The facts involve payment for an electronically delivered software licence to a treaty country resident without a permanent establishment in India and without PAN. The questions concern the interaction between statutory higher withholding for non furnishing of PAN and entitlement to treaty relief, and whether any statutory obligation to gross up payments exists versus contractual allocation of tax burden. Discussion-Forum Income Tax Mon, 04 May 2015 16:30:38 +0530 https://www.taxtmi.com/forum/issue?id=108530