Powers of the Commissioner (Appeals)

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....ppeals) 186. (1) In disposing of an appeal, the Commissioner (Appeals), shall have the following powers, namely:-     (a) in an appeal against an order of assessment, he may confi....

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....onsider and decide any matter which was not considered by the Assessing Officer. (3) The Commissioner (Appeals) shall not enhance an assessment or a penalty or reduce the amount of refund unless th....