Powers of Commissioner (Appeals).

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..... mmissioner (Appeals), shall have the following powers, namely:— (a) in an appeal against an order of assessment he may confirm, reduce, enhance or annul the assessment; (b) in .....

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..... e Commissioner (Appeals) shall not enhance an assessment or a penalty or reduce the amount of refund unless the appellant has had an opportunity of showing cause against such enhancement or reduction. .....

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