https://www.taxtmi.com/caselaws?id=337555 Section 206AA is procedural and cannot displace the beneficial treaty rate under section 90(2) or the special withholding rate under section 115A(1)(b) for payments to non-residents. The article states that PAN non-furnishing does not justify deduction at 20% where the applicable DTAA or section 115A prescribes a lower rate, because a withholding provision cannot override the treaty framework or the specific statutory rate. It also notes that, on the recorded facts, the material was sufficient to support application of the treaty or special-rate provisions, so a residual demand based only on further verification was not justified. en-us Wed, 23 Nov 2016 00:00:00 +0530 Fri, 05 Aug 2022 18:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337555 Section 206AA is procedural and cannot displace the beneficial treaty rate under section 90(2) or the special withholding rate under section 115A(1)(b) for payments to non-residents. The article states that PAN non-furnishing does not justify deduction at 20% where the applicable DTAA or section 115A prescribes a lower rate, because a withholding provision cannot override the treaty framework or the specific statutory rate. It also notes that, on the recorded facts, the material was sufficient to support application of the treaty or special-rate provisions, so a residual demand based only on further verification was not justified. Case-Laws Income Tax Wed, 23 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337555