JYOTI LIMITED,,VADODARA vs. DCIT,(INTERNATIONAL TAXATION), , BARODA

In the result, the appeal filed by the assessee is allowed

Bench: Shri Pradip Kumar Kedia& Ms. Madhumita Roy

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

THE DCIT, CENTRAL CIRCLE-2(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is allowed