DTAA prevails over Section 206AA even if non-resident does not have a PAN: SC

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 dispute arose when th...