Appeal powers: Commissioner (Appeals) may confirm, reduce, enhance or annul assessments; reasonable opportunity before enhancement required.

The Commissioner (Appeals) may confirm, reduce, enhance or annul assessments and may set aside assessments made under section 144 to refer for fresh assessment; where Settlement Commission proceedings abate the Commissioner may rely on materials from those proceedings to decide the appeal. In penalty appeals the Commissioner may confirm, cancel or vary penalties. The Joint Commissioner (Appeals) has equivalent powers. An enhancement of assessment or penalty, or reduction of refund, is permissible only after giving the appellant a reasonable opportunity to show cause, and appellate authorities may decide matters not previously raised by the appellant.

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