In the light of the judgement of the ITAT Pune in Serum Institute, Chirag Wadhwa argues that the approach of the department that even foreign entities entitled to the benefit of the DTAA should be subjected to a higher rate of TDS u/s 206AA for failure to quote the PAN is impractical and hinders the process of an effective and efficient taxation regime. He urges the department to take a holistic approach of the matter and ensure that while the noble object of detecting tax evasion is achieved, taxpayers are not put to unnecessary harassment