Definition of record clarified to include all records available at Commissioner's examination, permitting revision subject to appeal bar. The term 'record' in section 263(1) is declared to include all records relating to any proceeding available at the time of examination by the Commissioner ... Summary
Definition of record clarified to include all records available at Commissioner's examination, permitting revision subject to appeal bar.
The term 'record' in section 263(1) is declared to include all records relating to any proceeding available at the time of examination by the Commissioner and is "deemed always to have included" such material; this clarification resolves judicial controversy and confirms the Commissioner's competence to revise assessing officer orders except on matters already decided in appeal.
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