Non-resident without PAN subject to 11.33% TDS u/s 115A(1)(b), not 20%, per section 195.

Rate of withholding tax u/s 195 - non-resident not having PAN - the payment is well covered u/s 115A(1)(b) - special rate of TDS i.e. 11.33% was applicable - TDS @20% is not warranted AT .....

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