Payments to Non Residents – Grossing Up and Section 206AA
By CA Puja Borar
The provisions of Section 195 read with Section 206AA has been surrounded with increased controversies and complexities. This Article seeks to discuss the interoperability of Section 195, 195A and Section 206AA in the light of judicial pronouncements in relation to the same. It intends to analyze the various possible ways of determining the withholding tax in respect of remittance made to a non-resident beneficiary in the absence of PAN.