https://www.taxtmi.com/caselaws?id=471777 Section 90(2) gives a non-resident the benefit of a more favourable Double Taxation Avoidance Agreement rate over domestic tax provisions. Section 206AA, which prescribes higher tax deduction where PAN is not furnished, operates procedurally and does not override that treaty protection. Accordingly, royalty and fees for technical services paid to non-residents may be subject to tax deduction at the applicable beneficial treaty rate despite the absence of PAN, rather than the higher domestic withholding rate. en-us Tue, 24 Jun 2025 00:00:00 +0530 Thu, 17 Sep 2026 13:50:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471777 Section 90(2) gives a non-resident the benefit of a more favourable Double Taxation Avoidance Agreement rate over domestic tax provisions. Section 206AA, which prescribes higher tax deduction where PAN is not furnished, operates procedurally and does not override that treaty protection. Accordingly, royalty and fees for technical services paid to non-residents may be subject to tax deduction at the applicable beneficial treaty rate despite the absence of PAN, rather than the higher domestic withholding rate. Case-Laws Income Tax Tue, 24 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471777