DTAA overrides Section 206AA TDS rate

CIT Vs Wipro Ltd (Karnataka High Court) Facts of the Case: Assessee had paid fee for technical services to various entities in the four quarters during the AY 2011-12 and contended that the Tax Deducted at Source will be in terms of the relevant Article in respective agreements for Avoidance of Double Taxation in various countries. Assessee’s Contention: Placing reliance in the case of Danisco India Pvt. Ltd., Vs. Union of India, the assessee submitted that DTAA has an overriding effect and any subsequent amendment to nullify the effect of provision prior to the amendment has been read down...