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Powers of the Commissioner (Appeals)

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..... ) 186. (1) In disposing of an appeal, the Commissioner (Appeals), shall have the following powers, namely:- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul th .....

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..... r. (3) The Commissioner (Appeals) shall not enhance an assessment or a penalty or reduce the amount of refund unless the appellant has had a reasonable opportunity of showing cause against such enhanc .....

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