Overseas businesses in DTAA countries must provide PAN; tax rates follow treaty rules, not domestic laws.

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Full Text of the Document

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....Requirement to furnish Permanent Account Number (PAN) - where the deductee i.e the overseas resident business concern conducts its operation from a territory, whose Government has entered into a Double Taxation Avoidance Agreement with India, the rate of taxation would be as dictated by the provisions of the treaty.....