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.in view of the reasons we have stated above with respect to the sole ground of appeal, we have to conclude that this appeal is bound to fail . The court observed that: In the circumstances, if the intention of the appellant from the outset was to challenge the assessment of the respondent in respect of the disallowed direct sales costs based on the issue of non-compliance of the respondent with section 97 (c) of the ITA, she would have indicated so directly in her statement of appeal at the TRAB and later at the TRAT to enable them to deliberate and decide upon that legal question

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Young adult susceptible non-smokers and smokers responses to capsule cigarettes

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