under Art.226/227 of the Constitution praying
to declare that S.206AA of the Income Tax Act, 1961 is unconstitutional,
etc.
The Petitions coming ... Permanent Account Number (PAN) is communicated, pursuant to the
amendment to S.206AA of the Finance Act, 2009 based on which
appeal of
the assessee holding that DTA provisions will override
section 206AA of the act even if it is inconsistent with
Income ... 2010
whereby it is clearly stated that provisions of section
206AA will also apply to non-residents where TDS is
deducted on payments or credits
whichever is lower even though as per
Section 195 or Section 206AA nor under Section
90(2) of the Act do not contemplate such
restriction ... justified in holding
that the DTAA overrides the provisions of Section
206AA of the Act without appreciating that
Section 90(2) of the Act, which
case, the Tribunal is justified in holding that the provisions
of Section 206AA of Act relating to deducting of tax at
higher rate ... compliance of Section
195 of the Act by holding that Section 206AA of Act is
applicable as PAN was not quoted in respect
case, the Tribunal is justified in holding that the provisions
of Section 206AA of Act relating to deducting of tax at
higher rate ... compliance of Section
195 of the Act by holding that Section 206AA of Act is
applicable as PAN was not quoted in respect
levied at a higher rate at 20% in accordance with section
206AA of the Act?
6. Whether the Hon'ble Tribunal was right
levied at a higher rate at 20% in accordance with section
206AA of the Act?
6. Whether the Hon'ble Tribunal was right
levied at a higher rate at 20% in accordance with section
206AA of the Act?
6. Whether the Hon'ble Tribunal was right
levied at a higher rate at 20% in accordance with section
206AA of the Act?
6. Whether the Hon'ble Tribunal was right
levied at a higher rate at 20% in accordance with section
206AA of the Act?
6. Whether the Hon'ble Tribunal was right
