Tribunal held that provision of section 206AA has to be read down to mean that where deductee, i.e., overseas resident business concern, conducts its operation from a territory, whose Government has entered into a Double Taxation Avoidance Agreement with India, rate of taxation would be as dictated by provisions of treaty, i.e., 10 per cent instead of 20 per cent as prescribed in section 206AA. Of the Act. (AY. 2017-18 to 2009-10)