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.Appeal of Revenue is dismissed. No substantial question. of law.  (AY. 2018 19)