https://www.taxtmi.com/caselaws?id=337555 Section 206AA does not override the beneficial withholding rate available to non-residents under an applicable DTAA or the special rate under section 115A(1)(b). For royalty and fees for technical services, the higher withholding rate triggered by non-furnishing of PAN cannot displace the charging and treaty framework. Where payments were made through banking channels for identified services, recipients had no permanent establishment in India, and the deductor applied the relevant treaty or special-rate provisions, further verification alone did not justify a residual short-deduction demand. The short-deduction demand based solely on section 206AA was set aside. 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 does not override the beneficial withholding rate available to non-residents under an applicable DTAA or the special rate under section 115A(1)(b). For royalty and fees for technical services, the higher withholding rate triggered by non-furnishing of PAN cannot displace the charging and treaty framework. Where payments were made through banking channels for identified services, recipients had no permanent establishment in India, and the deductor applied the relevant treaty or special-rate provisions, further verification alone did not justify a residual short-deduction demand. The short-deduction demand based solely on section 206AA was set aside. Case-Laws Income Tax Wed, 23 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337555