prescribed under DTAA, but as per the higher rate
prescribed under Section 206AA .
• The precise question for adjudication before the Special Bench was
that whether ... provisions of DTAA would be applied or whether the
provisions of Section 206AA would supersede the provisions of DTAA.
• Deciding the case in favour
Board is clearly applicable.
(6) ALTERNATIVELY; in terms of section 206AA read with section 139A of
Act and Article 14 of The Constitution of India ... scrutiny of Article 14 of the constitution for reasonableness.
But, section 206AA which is contrary to section 139A appears to be
discriminatory
Board is clearly applicable.
(6) ALTERNATIVELY; in terms of section 206AA read with section 139A of
Act and Article 14 of The Constitution of India ... scrutiny of Article 14 of the constitution for reasonableness.
But, section 206AA which is contrary to section 139A appears to be
discriminatory
Board is clearly applicable.
(6) ALTERNATIVELY; in terms of section 206AA read with section 139A of
Act and Article 14 of The Constitution of India ... scrutiny of Article 14 of the constitution for reasonableness.
But, section 206AA which is contrary to section 139A appears to be
discriminatory
levy of TDS at the rate
of 20% in terms of section 206AA .
2.5 We have heard the rival contentions and perused the material available ... Jaipur vs. ITO(TDS)-1, Jaipur
2.6 Further, we refer to section 206AA which provides as under:
(1) Notwithstanding anything contained in any other provisions
assessee also submitted that as per provision of section 206AA
read with section 139A of the Act and as per the article ... scrutiny of article 14 of the
constitution for reasonableness. But, section 206AA which is contrary to
section 139A appears to be discriminatory
assessee also submitted that as per provision of section 206AA
read with section 139A of the Act and as per the article ... scrutiny of article 14 of the
constitution for reasonableness. But, section 206AA which is contrary to
section 139A appears to be discriminatory
assessee also submitted that as per provision of section 206AA
read with section 139A of the Act and as per the article ... scrutiny of article 14 of the
constitution for reasonableness. But, section 206AA which is contrary to
section 139A appears to be discriminatory
assessee also submitted that as per provision of section 206AA
read with section 139A of the Act and as per the article ... scrutiny of article 14 of the
constitution for reasonableness. But, section 206AA which is contrary to
section 139A appears to be discriminatory
assessee also submitted that as per provision of section 206AA
read with section 139A of the Act and as per the article ... scrutiny of article 14 of the
constitution for reasonableness. But, section 206AA which is contrary to
section 139A appears to be discriminatory
