TDS Rate for Non-Residents Governed by DTAA, Not Section 206AA: Delhi HC

CIT, International Taxation Vs Air India Ltd. (Delhi High Court) The Delhi High Court heard an Income Tax Appeal challenging the order dated 23rd April 2021 passed by the Income Tax Appellate Tribunal (ITAT) in ITA Nos. 2260/DEL/2018, 2261/DEL/2018, and 2262/DEL/2018 concerning Assessment Year 2013-14. The appellant contended that the ITAT erred in holding that Section 206AA of the Income Tax Act, 1961, which mandates higher tax deduction rates for non-residents without PAN, could not override the provisions of the Double Taxation Avoidance Agreement (DTAA). The appellant argued that Section 2...