https://www.taxtmi.com/caselaws?id=797865 Section 90(2) gives priority to a Double Taxation Avoidance Agreement where its provisions are more beneficial to the assessee. Section 206AA operates as a procedural tax-withholding requirement and does not displace a beneficial treaty rate for payments to non-residents. Tax need not be deducted at the higher rate solely because the non-resident deductee has not furnished a permanent account number when the applicable treaty prescribes a lower rate. The treaty rate consequently governs tax deduction at source in such circumstances. en-us Thu, 20 Aug 2026 00:00:00 +0530 Fri, 28 Aug 2026 20:42:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797865 Section 90(2) gives priority to a Double Taxation Avoidance Agreement where its provisions are more beneficial to the assessee. Section 206AA operates as a procedural tax-withholding requirement and does not displace a beneficial treaty rate for payments to non-residents. Tax need not be deducted at the higher rate solely because the non-resident deductee has not furnished a permanent account number when the applicable treaty prescribes a lower rate. The treaty rate consequently governs tax deduction at source in such circumstances. Case-Laws Income Tax Thu, 20 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797865