Section 206AA Does Not Override DTAA: Tax Deduction at 10% Valid Without PAN in India-Netherlands Case.

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....TDS at the higher rate of 20% in case of payee without PAN under the provisions contained u/s 206AA - CIT (A) has erred in holding that in this case, provisions contained u/s 206AA overrides beneficial provisions of DTAA between India and Neitherland. Consequently, assessee has rightly deducted the tax @ 10% as per provisions contained under DTAA as section 206AA cannot have overriding effect on DTAA, hence no demand is payable by the assessee. - AT....