Tax Rates for Non-Residents: DTAAs Override Section 206AA's 20% Rate Without PAN u/s 90(2.

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....Enhanced rate of TDS @20% in the absence of PAN - section 206AA of the Act does not override the provisions of section 90(2) of the Act and that in the impugned cases of payments made to non-residents, assessee correctly applied the rate of tax prescribed under the DTAAs and not as per section 206AA - AT....