Appellate authority powers allow modification of assessments and penalties but require opportunity to show cause.

The Commissioner (Appeals) may confirm, reduce, enhance or annul assessments and confirm, cancel or vary penalties, and determine issues in other appeals; may consider matters not considered by the Assessing Officer; must provide the appellant an opportunity to show cause before enhancing an assessment or penalty or reducing a refund; and may decide any matter arising out of the proceedings even if not raised by the appellant.

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