JYOTI LIMITED,,VADODARA vs. DCIT,(INTERNATIONAL TAXATION), , BARODA
In the result, the appeal filed by the assessee is allowed
ITA 666/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad22 Mar 2021AY 2014-15
Bench: Shri Pradip Kumar Kedia& Ms. Madhumita Roy
For Appellant: ShriManish Shah, ARFor Respondent: ShriR. K. Makwana, SR. DR
Section 201Section 206A
TDS @ 20%,
DTAA would override the provision of this particular domestic Act since the provision of DTAA are more beneficial to the assessee.In this regard we have considered the Article 12 of DTAA which prescribes such rate of tax to be deducted @ 10%.
7. We have considered the Section 206AA of the Income Tax Act which reads as follows
