The Supreme Court has ruled that tax deduction at source (TDS) on remittances to non-resident entities cannot exceed 10%, as stipulated by Double Tax Avoidance Agreements (DTAA). Rejecting the Income Tax Department's appeal for a higher 20% rate, the apex court clarified that DTAA benefits prevail over Section 206AA when Permanent Account Numbers are absent. This landmark decision offers significant relief to Indian IT firms like Mphasis, Wipro, and Manthan Software Services regarding their foreign payments.