Lower tax rate under tax treaty applies (even absent a permanent account number):

The Special Bench of the Hyderabad Income-tax Appellate Tribunal held that certain tax law provisions do not override provisions of an applicable income tax treaty, to the extent that the treaty provisions are beneficial to the taxpayer. The case is: Nagarjuna Fertilizers and Chemicals Ltd. Read a February 2017 report [PDF 322 KB] of KPMG