This discussion addresses the TDS rate applicable to External Commercial Borrowings (ECB) interest paid to non-residents when their PAN is unavailable. While Section 194LC typically allows a concessional TDS rate of 5%, the absence of a PAN could lead to a significantly higher TDS rate, potentially up to 20%.
1) External Commercial Borrowings Loan Taken before 01-07-2023. 2) TDS as per 194LC 5% concessional rate is applicable. 3) PAN of Non Resident Not Available.
Kindly throw some light on TDS Rate, if Non Resident is not having PAN.
Will still be 5% concessional rate available or TDS should be deducted at Heigher Rate?