As per section 206AA, a declaration in Form No. 15G or Form No. 15H is not a valid declaration, if it does not contain PAN of the person making the declaration. If the declaration is without the PAN, then tax is to be deducted at higher of following rates:
• Rate specified in the relevant provision of the Act
• Rate or rates in force, i.e., the rate prescribed in the Finance Act
• At the rate of 20%.
Agree with Ms. Roohi Rasheed. If you don’t have the PAN then you cant file the VALID 15G/15H also you could not apply for lower deduction of tax under section 197. In that case, you’ll be simply covered under section 206AA and tax shall be deducted @ The rates given in the act OR 20% whichever is higher.