Section 206AA not overrides beneficial provisions of DTAA with Neitherland

Air India Limited Vs ITO (ITAT Delhi) Undisputedly, the dispute in the instant appeals is qua applying the TDS rate at 12% or 10% on transfer between ELFC and the assessee for taking an engine on lease under an Agreement. It is also not in dispute that ELFC, the lessor is a foreign company having no Permanent Establishment (PE) and was a tax resident of Neitherland. It is also not in dispute that under Article 7 of Double Taxation Avoidance Agreement (DTAA) between India and Neitherland, the profits of enterprise of a contracting state shall be taxable only in that state unless the enterprise ...