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

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