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Section 94 in Finance Act, 2020 94. Amendment of section 206AA. - In section 206AA of the Income-tax Act, in sub-section (1), the following

Bang/2018 the rate as prescribed in Section 206AA of the Act as the PAN was not provided by the recipients.The assessee has made ... terms of DTAA and the provisions of Section 206AA of the Act. The Assessing Officer is of the opinion that the assessee should have deducted

assessee had not deducted tax at the rates provided in section 206AA of the Income Tax Act, 1961 (hereinafter called ... provided u/s 206AA of the Act for the purposes of deduction of tax at source from payment made by 4 ITA No. 1039

Learned Assessing Officer observed that as per the provisions of section 206AA of the Income Tax Act, 1961 (for short ... rate or rates specified in DTAA and 20% as per section 206AA of the Act, passed the order dated 4/3/2015 under section

whom the payments were made. As per the provisions of sec.206AA of the Income ... been applied was the higher rate of tax in terms of Sec.206AA of the Act. Therefore, the demand to the extent of short deduction

appeal of the assessee on the issue of applicability of section 206AA of the Income-tax Act, 1961, in respect of payments made ... rate of 30%, as provided under the provisions of Section 206AA when the benefit of DTAA is available, despite the overriding effect of Section 206AA

deducted is not at higher rate as prescribed by Sec.206AA of the Act but at the rate applicable as per the Treaty for Double ... India and the country of which the payees were tax residents. Section 206AA was introduced from FY 2010-11. Section 206AA requires every taxpayer

having a Permanent Account Number (PAN), as mandated U/s.206AA of the I.T.Act, 1961, and such payments effected to the Non-resident ... which, in turn, override the DTAAs provisions especially section 206AA of the Act which is the controversy before us. Therefore, in our view, where

having a Permanent Account Number (PAN), as mandated under Section 206AA of the I.T. Act, 1961 and such payments effected to the Non-resident ... which, in turn, override the DTAAs provisions especially section 206AA of the Act which is the controversy before us. Therefore, in our view, where

facts of the case in coming to the conclusion that Section 206AA of IT Act does not override the provision of Section ... despite the fact that Sec.206AA starts with a non­obstante clause? [B] Whether the Appellate Tribunal has erred in law and on facts