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Appeals to the Commissioner (Appeals).

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..... d under this Act, or objecting to any penalty or fine imposed by the Assessing Officer, or to the amount allowed by the Assessing Officer by way of any relief under any provision of this Act, or to any refusal by the Assessing Officer to grant relief or to an order of rectifi cation having the effect of enhancing the assessment or reducing the refund, or to an order refusing to allow the claim mad .....

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..... e appellant had sufficient cause for not presenting it within that period. (4) The Commissioner (Appeals) shall hear and determine the appeal and, subject to the provisions of this Act, pass such orders as he thinks fit and such orders may include an order enhancing the assessment or penalty : Provided that an order enhancing the assessment or penalty shall not be made unless the person affected t .....

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