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Who wins?

Impossible to say really. How does Atum fare vs non gods? He's never fought someone who wasn't a god. His whole shtick is devouring gods. He's never fought a cosmic before (like Galactus or a Celestial).

Depending on how Tyrant's powers work (with that hole BSE absorption even when it's converted to other energy types), he can probably absorb Atum.

I'm going with Tyrant.

Atum was just recently revealed to not only be capable of consuming magical beings but when any magical entity dies, regardless of how ,there soul is consumed by him in the after life

This would theoreticly mean atum has his power+ the power of every Magical Being who ever died in the marvel universe..

Just goes to show how retarded the skrull arc was wtf...