Where whole payment would not be income chargeable to tax in the hands of recipient non-resident, person responsible for paying such sum may make application for determination of appropriate portion

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....onsible for paying such sum may make application for determination of appropriate portion 1. I am directed to state that section 195 imposes a statutory obligation on any person responsible for paying to a non-resident any interest (not being "interest on security") or any other sum (not being dividends) chargeable under the provisions of the Income-tax Act to deduct income-tax at the "rates in f....

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....d not be income chargeable under the Income-tax Act in the case of the recipient non-resident, he may make an application under section 195(2) to the Income-tax Officer for the determination of the appropriate portion of such payment which would be taxable and in respect of which tax is to be deducted under section 195(1). 3. The object of section 195 is to ensure that the tax due from non-reside....