Appeals to the Commissioner (Appeals).

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..... ility to be assessed under this Act; or (c) objecting to any penalty imposed by the Assessing Officer; or (d) objecting to an order of rectification having the effect of enhancing the assessment or reducing the refund; or (e) objecting to an order refusing to allow the claim made by the assessee for a rectification under section 12, may appeal to the Commissioner (Appeals). (2) Every appeal sha .....

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..... is Act, pass such orders as he thinks fit and such orders may include an order enhancing the assessment or penalty: Provided that an order enhancing the assessment or penalty shall not be made unless the assessee has been given a reasonable opportunity of being heard. - Clause.-15 relates to appeals before the Commissioner (Appeals) and, inter alia , provides that any person may file an a .....

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