After withholding to non-resident @ 20% without PAN, no receipts?

USA company that has issued Indian company (payor) their USA Certificate of Tax Residency, did not want to apply for a PAN and be liable for tax returns etc in India (understandable). USA company is asking for the tax withholding receipts based on the amount Indian company withheld and paid, so USA company can offset the amount they lost or that was withheld from India as a Foreign Tax Credit for their USA tax return. Does the Indian tax office not issue such tax withholding receipts when no PAN was issued from USA company so Indian company can prove to USA company that such amounts were actually paid to Indian tax office and the exact amount tax withheld? This sounds like harassment to get them to apply for PAN. Note: USA company did issue a TAX Residency Certificate. So not sure why maximum was withdeld for technical services when it should be at least reduced 10% or less. No PAN No residency certificate will make sense to withhold 20% but if either PAN or Residency Certificate is issued, then reduced withhold rate should apply of 10% or less. Comments appreciate this. Hope I have misunderstood something.