DTAA Provisions Override Section 206AA, 10% TDS Rate Applies to Non-Residents Despite PAN Requirement.

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....Rate of TDS - payment to non residents - @25% u/s 206AA in the absence of PAN or 10% as per DTAA - where the tax has been deducted on the strength of beneficial provisions of DTAA, provisions of section 206AA of the Act cannot be invoked by the Assessing Officer to insist that the tax deduction should be @ 20%....