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Dtaa v/s 206aa

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Querist : Anonymous (Querist)
26 May 2015 Can a company take the benefit of DTAA TDS rates when the PAN of non resident (foreign company) is not available.
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CA. SHIVA SHANKARA R. SHETTY

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CA. SHIVA SHANKARA R. SHETTY (Expert)
27 May 2015 Prima facie, DTAA is applicable to the foreign citizen and not to Indian citizen.

Being a company registered in India is deemed to be Indian citizen and Resident in India. Therefore, it has to comply with the TDS provisions under the Income Tax Act, 1961

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