Section 206AA cannot have overriding effect on DTAA

CIT International Taxation Vs Air India Ltd. (Delhi High Court) Whether ITAT has erred in holding that the rate of deduction of tax in the case of a non-resident who does not have a PAN and whose case does not lie in the exceptions laid down in Sub-Section 7 of Section 206AA of the Act shall be the rate prescribed in the DTAA if such rate is lower than the rate specified in the relevant provisions of the Act and not as per the provisions of Section 206AA of the Act? A perusal of the paper book reveals that in the present case the ITAT has held that it is not in dispute that the engine is a par...