DTAA Taxation

If a Foreign Company having PE in india providing online advertisement services then section 195 would be attracted for TDS. 
My doubt is that is DTAA exists and rate as per DTAA 20%, then by which rate TDS is to be deducted either 20% or 40%
Replies (1)
Tds to be deducted by rate which is beneficial to assessee i.e 20%

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