Appellate Authority's Power Limited: Cannot Alter Transaction Character u/s 52(3), Only Confirm, Cancel, or Vary Orders.

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....Power of First Appellate Authority to change the character of the transaction - the correct interpretation to be given to clause (b) of Section 52(3) is to mean that the power is exercisable in the case of any other order which can be confirmed, canceled or varied, provided it does not change the character of the transaction nor the subject matter which was the issue before the Assessing Officer. - HC....