Supreme Court Rules PAN Not Mandatory for DTAA Benefits: TDS Capped at 10% for Foreign Payments

Last updated: 29 November 2025

The Supreme Court has ruled that Indian companies cannot be compelled to deduct more than 10% TDSon payments made to foreign companies if a Double Tax Avoidance Agreement (DTAA) applies. The apex court categorically held that tax treaties override domestic tax provisions, including Section 206AA of

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