The Revenue filed an appeal challenging the order of the Tribunal before the Hon’ble Karnataka High Court wherein it had to be decided whether the provision of section 206AA starting with a non-obstante clause overrides all provisions of the Income Tax Act, 1961 and as such provisions of the Double Taxation Avoidance Agreement would not override the provisions of the Income Tax Act, 1961. However, the Hon’ble Court relied on the decision in case of CIT (IT) v. Wipro Ltd. [2023] 22 ITR-OL 371 (Karn.)(HC)  to hold that the instant case would be covered by the said decision thereby re-confirming the view that provisions of the Income-Tax Act, 1961 could not override the provisions of Double Taxation Avoidance Agreement.