Section 206AA's higher tax rates for non-residents without PAN don't override DTAA benefits, per Section 90(2).

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Full Text of the Document

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....Withholding of tax at higher of the rates prescribed u/s 206AA - non-resident not having PAN - provision of section 206AA will not have an overriding effect over the provisions of the 1961 Act and if the provision of DTAA are beneficial to the assessee they will override provisions of Section 206AA by virtue of provisions of Section 90(2). - AT....