Refund for denying liability to deduct tax in certain cases - Section 239A

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.... 239A ] * Where under an agreement or other arrangement, in writing, the tax deductible on any income, other than interest, under section 195 is to be borne by the person by whom the income is payab....

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....order in writing, allow or reject the application: [ Section 239A(2) ] * Provided that no application u/s 239A(1) shall be rejected unless an opportunity of being heard has been given to the applica....