Dear Forum

Indian company received service from non resident company and deducted tax at source @ 20% as the overseas payee does not have PAN in india.

There is DTAA between the two countries but the 20% rate was applied as the payee could not provide its TRC of its home country.

While processing Form 144 (prev 27Q), ITD has applied 20.8% tds rate and demanded the difference.

Is this correct as per law.

Please advise.

Regards

CA Dipjyoti Majumdar