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In favour of revenue.Having considered the material on record and the law laid down by the Apex Court in regard to the power of Commissioner (Appeals) exercisable under Section 251 of the Act, we are of the considered opinion that the order of the Tribunal needs no interference and the appeal of the assessee is dismissed.

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Section 251 of the Income Tax Act, 1961— Commissioner (A) — While exercising power under section 251, Commissioner (A) can confirm, reduce, enhance or annul assessment  and power exercisable by Commissioner (A) under section 251 cannot be restricted only to issues raised in appeal before him — S D Traders vs. Commissioner of Income tax [2019] 267 Taxman 631 (Allahabad)

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