Can TDS Rate Exceed DTAA Rate? Examining Section 206AA's Impact on Tax Deduction Without PAN.

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....Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT....