Assessee made payments to non-residents without deducting tax at source, claiming exemption under DTAA.  Revenue contended that provisions of section 206AA overrides DTAA, requiring higher tax rate for non-PAN furnishers. Commissioner (Appeals) as well as Tribunal held that DTAA provisions overrides section 206AA.  High Court held that in view of decision of CIT (IT) v. Wipro Ltd. (2023) 146 taxmann.com 129 (Karn)(HC)  [2023] 146  and connected matters, Tribunal and Commissioner (Appeals) were right in holding that provisions of DTAA overrides provisions of section 206AA and rate of tax to be applied for grossing up should be as per DTAA. Revenue filed   SLP along with an application for condoning delay of 402 days.   Court held that since application seeking condonation of delay did not assign any satisfactory reasons for delay nor were they sufficient in law to be condoned, SLP is  dismissed. (AY. 2018 19)