Liability to deduct tax: payer may seek a declaration that withholding was not required after paying tax to government. Where an agreement makes the payer bear withholding, a payer who has paid tax to the Central Government may appeal to the Commissioner (Appeals) for a declaration that no tax was deductible; the remedy addresses the payer's contention about legal withholding obligations. An amendment by the Finance Act, 2022 limits application based on the date of tax payment, and case law confines appeals to disputes over chargeability of the nonresident recipient's income rather than creating an assessment procedure against the payer.