2023 (6) TMI 1406

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..... ng of tax at higher rate in the absence of Permanent Account Number to the payments made to Non Resident Companies - ITAT confirmed non applicability of provision of 206AA on the ground that benefit of DTAA is available to the assessee - assessing authority rightly held that assessee is to be in default for non-compliance of Section 195 of the Act by holding that Section 206AA of Act is applicable .....

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..... TANDING COUNSEL JUDGMENT This appeal by the Revenue challenging the order dated April 11, 2022 in IT(IT)A No.4/Bang/2014 for the A.Y.2011-12 has been filed to consider the following questions of law: 1. Whether, on the facts and in the circumstances of the case, the Tribunal is justified in holding that the provisions of Section 206AA of Act relating to deducting of tax at higher rate in the absen .....

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..... dated 24/6/2016 issued by CBDT only relaxed the condition of the tax at high rate under section 206AA in case of Non- Residents only if the deductee furnishes details and documents specified in sub clause(2) of the notification? 2. To a pointed question as to whether the issues raised in this appeal are covered by the decision of this court in The Commissioner of Income-tax and Another Vs. M/s.WI .....

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