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Provisions in relation to appeals.
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10.—(1) Whenever an appeal is made against an assessment made under Schedule D of the Income Tax Act, 1918 or according to the rules applicable to that Schedule or under Schedule E of the said Act, the appellant shall in the notice of appeal specify the grounds of the appeal, but this sub-section shall not preclude the Special Commissioners from allowing the appellant on the hearing of the appeal to go into any ground of appeal which was not specified in the notice of appeal and the omission of which from such notice was in the opinion of the Special Commissioners not wilful or unreasonable.
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beyond the time appointed for hearing appeals, such assessment shall pending the determination of the appeal be deemed to be final and conclusive in respect of such amount of the tax thereby assessed as appears to the Special Commissioners not to be in dispute and pending such determination that amount of the tax shall be collected and paid in all respects as if it were tax charged by an assessment in respect of which no appeal was pending and on the determination of such appeal any balance of tax chargeable in accordance with such determination shall be payable or any tax overpaid shall be repaid, as the case may require.
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