Appeal to Commissioner(Appeals).

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..... ssee 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 .....

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..... tion 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 .....

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