D.—APPEALS AND REVISION
Appeal to Commissioner(Appeals).
178. (1) An assessee may prefer an appeal to the Commissioner (Appeals) where he is aggrieved by or an intimation issued or an order passed by any income-tax authority below the rank of the Commissioner as specified in the Twenty-First Schedule.
(2) Without prejudice to sub-section (1), the assessee may prefer an appeal—
(i) where an application filed by him under section 161 has not been disposed of by the Assessing Officer within a period of six months from the date of filing of the application; or
(ii) where he is required to bear the liability in respect of the tax deductible under section 195 on the income payable to a non-resident under any agreement or other arrangement and—
(a) he claims that no tax was deductible by him on such income payable by him to the non-resident; and
(b) has paid the tax on such income to the credit of the Central Government.
