Double Taxation Avoidance Agreement Takes Precedence Over Income Tax Act, Highlights Importance of International Agreements in TDS Applications.

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....TDS u/s 195 - Rates specified in Section 206AA - The Special Bench held that DTAA overrides the Act, even if it is inconsistent with the Act. DTAAs are entered into between two nations in good faith and are supposed to be interpreted in good faith. Otherwise it would amount to the breach of Article 253 of the constitution - AT....