Trc requirement on payment to non-resident

Urgent Query.

Independent Personal Services as per Article 15 of DTAA exempted from withholding tax / TDS.

As per Section 90 (2) of Income Tax Act, 1961 : Tax Residency Certificate (TRC) from the country of residence of the non-resident is compulsory to avail the benefit of DTAA.

In the present case, is the benefits of DTAA are still available withour TRC.