WITHHOLDING (TDS) RATE ON PROFESSIONAL/FEES FOR TECHINCAL SERVICE PAYMENT TO NRI

WHAT WILL BE THE WITHHOLDING / TDS RATE ON FEES FOR TECHNICAL SERVICE PAID TO NRI (RESIDENT OF USA). PLEASE NOTE, TRC OF THE NRI IS NOT AVAILABLE. CAN BENEFIT OF DTAA BE CLAIMED. WHAT IS THE TAX RATE AS PER INDIAN INCOME TAX ACT AND DTAA OF USA ON FTS. AS PER MY UNDERSTANDING IF THE RECEIVER DOES NOT HAVE PAN - THEN TDS AT HIGHER RATE OF 20% IS TO BE DEDUCTED. WILL THIS PROVISON BE APPLICABLE HERE?

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