https://www.taxtmi.com/caselaws?id=433179 The ITAT dismissed all eighteen appeals filed by the Department, affirming the CIT(A)'s decision that the assessee was entitled to deduct TDS at the rates specified in the respective DTAAs, and not at the higher rate under Section 206AA. The ITAT emphasized that the beneficial provisions of DTAA should apply, and Section 206AA does not override Section 90(2). The ITAT also condoned a minor delay of 2 days in the Department's filing of the appeals. The judgment reiterated the precedence of DTAA provisions over Section 206AA when they are more beneficial to the assessee. en-us Fri, 20 Jan 2023 00:00:00 +0530 Mon, 23 Jan 2023 15:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433179 The ITAT dismissed all eighteen appeals filed by the Department, affirming the CIT(A)'s decision that the assessee was entitled to deduct TDS at the rates specified in the respective DTAAs, and not at the higher rate under Section 206AA. The ITAT emphasized that the beneficial provisions of DTAA should apply, and Section 206AA does not override Section 90(2). The ITAT also condoned a minor delay of 2 days in the Department's filing of the appeals. The judgment reiterated the precedence of DTAA provisions over Section 206AA when they are more beneficial to the assessee. Case-Laws Income Tax Fri, 20 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433179