Assessee Rightly Used DTAA Tax Rate Over Section 206AA for Payments to Non-Residents Without PAN, Per Section 90(2.

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....Rate of TDS - payments made to non-resident entities not having PAN - assessee correctly applied the rate of tax prescribed under the DTAAs and not as per section 206AA because the provisions of the DTAAs was more beneficial - section 206AA does not override the provisions of section 90(2)....