This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
DTAA prevails over Section 206AA even if non-resident does not have a PAN: SC
Case Law Details
- Case Name
- CIT & Anr. Vs Manthan Software Services Pvt. Ltd. (Supreme Court of India)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Supreme Court of India
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
CIT & Anr. v. Manthan Software Services Pvt. Ltd. (Supreme Court of India)
Supreme Court order on DTAA Rate vs. Section 206AA – Whether 206AA Overrides a Treaty Rate When Non-Resident Has No PAN
The Supreme Court in CIT & Anr. v. Manthan Software Services Pvt. Ltd. disposed of the Revenue’s SLPs after noting that the issue was already settled by its earlier judgment in CIT (International Taxation) v. Air India Ltd., thereby giving finality to the principle that DTAA provisions override Section 206AA even where a non-resident does not have a PAN. The underlying disp...
Author Info
