https://www.taxtmi.com/caselaws?id=60121 Section 195(2) of the Income-tax Act, 1961 is confined to determining the appropriate proportion of a remittance chargeable to tax, and cannot be used to obtain a declaration that the entire sum is wholly exempt. A claim of complete exemption must be addressed in the assessment of the non-resident recipient, not through an application under section 195(2). On that basis, an application seeking total exemption was misconceived, and an appeal arising from such an order was not maintainable. en-us Mon, 21 Apr 1986 00:00:00 +0530 Mon, 03 Jan 2011 17:49:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60121 Section 195(2) of the Income-tax Act, 1961 is confined to determining the appropriate proportion of a remittance chargeable to tax, and cannot be used to obtain a declaration that the entire sum is wholly exempt. A claim of complete exemption must be addressed in the assessment of the non-resident recipient, not through an application under section 195(2). On that basis, an application seeking total exemption was misconceived, and an appeal arising from such an order was not maintainable. Case-Laws Income Tax Mon, 21 Apr 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60121