TDS FOR NON RESIDENT.

Over which transaction TDS need to be deducted?

As I understand, TDS return will simply show “PAN not Available”.   Whether and how such non resident will show income in India is not something to be concerned about as far as the person deducting tax is concerned and once tax is deducted as required under s.195 or any other relevant section, compliance part for Indian Tax payer is complete.

Non resident could subsequently, if it feels that it is entitled to refund of amount and wishes to file return for that purpose, it could rely upon Transaction Based Report(TBR) for the purpose of claiming refund. 

You also need to understand however that tax is to be deducted against payment to a Non resident only if the amount being paid is chargeable to tax under ITA, 1961 and merely because NR may not have PAN will not necessarily require deduction of tax and DTAA/Tax Treaty between India and country of Non Resident may be carefully examined for withholding tax obligations.

Please consider this for broader understanding only.

DTAA AGREEMENT IS NOT APPLICABLE FOR ALL COUNTRIES. INDIA DOES NOT HV SUCH AGREEMENTS FOR ALL SUCH COUNTRIES.