Powers of Joint Commissioner (Appeals) or Commissioner (Appeals).

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..... appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment; (b) where such appeal is against an order of assessment made under section 271, the Commissioner (Appeals) may set aside the assessment and refer the case back to the Assessing Officer for making a fresh assessment; (c) in an appeal against the order of assessment for which the proceeding before th .....

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..... r a penalty or reduce the amount of refund, unless the appellant has had a reasonable opportunity of showing cause against such enhancement or reduction. (3) The Joint Commissioner (Appeals) or the Commissioner (Appeals), may consider and decide any matter arising out of the proceedings in which the order appealed against was passed, irrespective of the fact that such matter was not raised before .....

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