Moreover, Income-tax Act, 1961 cannot override DTAA. Its essential to have Tax Residency Certificate in place. You may find the attached writeup useful in this case.
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Discussion / Re: whether section 206AA will override DTAA?
February 20, 2014, 10:32:32 AM
Dear All,
First we need to check if the recipient was liable to tax in India and is he required to take a PAN in India? Eventhough sec. 206AA starts with a Non-obstante clause, it does refer to only those transactions on which tax is deductible as per chapter XVII-B.
First we need to check if the recipient was liable to tax in India and is he required to take a PAN in India? Eventhough sec. 206AA starts with a Non-obstante clause, it does refer to only those transactions on which tax is deductible as per chapter XVII-B.
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