provisions of clause (a). [ Similar to Section 203A , Section 206AA , Section 206CC , Section 200 , Section 206A , Section 206C , Section 194IA , Section 194IB , Section 194M , Section
37BC. Relaxation from deduction of tax at higher rate under section 206AA.
(1) In the case of a non-resident, not being a company ... deductee') and not having permanent account number the provisions of section 206AA shall not apply in respect of payments in the nature of interest, royalty
rate of five per cent. (2) If the provisions of section 206AA is applicable to a specified person, in addition to the provision of this ... higher of the two rates provided in this section and in section 206AA. (3) For the purposes of this section "specified person" means a person
Section 63 in Finance (No. 2) Act, 2014
63. Amendment of section 206AA.
- In section 206AA of the Income-tax Act, in sub-section
facts of the
case in coming to the conclusion
that Sec. 206AA of the I.T. Act
does not override the provisions
of Section ... despite the fact that section
206AA of the I.T. Act starts with
a non obstante clause?
(ii) Whether the Hon'ble ITAT
facts of the case in coming to the
conclusion that Sec. 206AA of the I.T. Act
does not override the provisions of Section ... despite the fact that
section 206AA of the I.T. Act starts with a
non obstante clause?
(ii) Whether the Hon'ble ITAT
that the ITAT has erred in
holding that the provisions of Section 206AA of the Income Tax Act,
1961 ('the Act') cannot override ... Avoidance Agreement without appreciating the fact that the provisions
of Section 206AA are non obstante provisions and therefore these
ITA No.233/2022 Page
deductee and, therefore,
in terms of subsection(6) of section 206AA of the Act, it
would have the effect as if the deductee ... deductor and the effect of provisions of sub
section(1) of section 206AA would follow. We may notice
that in terms of subsection
payments
are liable for TDS at the rate of20% as per section 206AA of
the IT Act, 1961
9.2 The learned CIT(A) has erred ... consequently there was no requirement to furnish its PAN
under section 206AA ;
4
IT(IT)A Nos.4 & 1182 /Bang/2014.
M/s.Infosys
Whether on the facts and circumstances of the case,
provisions of section 206AA of the Act will have a overriding
effect for all other provisions ... furnish valid Permanent Account Numbers
as per the provisions of section 206AA of the Act. In case of other non-
residents, who were the residents
