Appeal against liability to deduct tax allows a payer who bore deduction to seek a declaration of non-deductibility. Section 248 permits a person who, under an agreement, bore and paid tax deductible under section 195 on income other than interest to appeal to the Commissioner (Appeals) for a declaration that no tax was deductible. The appeal is available where the payer has paid such tax to the Central Government but claims that no deduction was legally required. A proviso restricts appealability for tax paid on or after a later specified date.