192.This section provides that appeals are to be allowed on only two grounds:
	that the notice against which the appeal was brought was not in accordance with the law; or
	where the notice involved the exercise of discretion by the Commissioner, that he should have acted differently.
193.The Tribunal may review any facts on which the notice was based and if it allows the appeal it may substitute the notice with another one.
Commentary on Sections Part V: Appeals Section 58: Determination of appeals