Day: November 29, 2025

DTAA Rate vs. Section 206AA: Withholding in the Absence of PAN – A Revisited and Settled Controversy

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  The interaction between treaty rates and Section 206AA has long generated uncertainty in cross-border withholding. One of the most common queries was whether non-furnishing of a PAN would necessarily result in compulsory 20 per cent deduction, despite being at variance with the net DTAA rate. This aspect has been clarified by the Delhi High Court … Read more

Judiciary Must Be an “Active Participant” Not a “Bystander” in Delivering Social Justice: Allahabad High Court

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  The Allahabad High Court, while analysing the responsibilities of the judiciary in safeguarding individual liberties, has held that the judiciary can’t function as a mere observer when vulnerable citizens approach for seeking justice. The Court stressed that the legal system must remain sensitive to social realities and actively intervene to prevent injustice. “Many of … Read more