TDS on Payments to Non-Resident Companies: DTAA's 10% Rate Prevails Over Section 206AA's 25% Rate Requirement.

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....Rate of TDS - payment to non residents - rate to be applied on the payments made by assessee to a non-resident company - @25% u/s 206AA in the absence of PAN or 10% as per DTAA - Sec.206AA overrides the provision of sec.90(2) or not - section 206AA of the Act cannot override the provisions of DTAA - AT....