As per DTAA TDS rate for royalty & technical fee PAID TO Germany is 15 % .And in this respect deductor is the Indian Co. Deduct TDS @20%+Surcharge+Ed.& HEd. Cess Because of deductee not having PAN in India.
Kindly confirm what is the actual rate of TDS in the aforesaid case for the F.Y.2013-14?