(2) A reassessment of a tax liability is to be made
in accordance with the legal interpretations and assessment practices
generally applied by the Chief Commissioner in relation to matters of that
kind at the time the tax liability arose except to the extent that any
departure from those interpretations and practices is required by a change in
the law (whether legislative or non-legislative) made after that time.
(3)
The Chief Commissioner cannot make a reassessment of a tax liability more than
5 years after an assessment of the liability, unless--
(a) the reassessment is
to adjust tax to give effect to a decision on an objection or review as to the
initial assessment, or
(b) at the time the initial assessment or a
reassessment was made, all the facts and circumstances affecting the liability
under the relevant taxation law of the person in respect of whom the
assessment or reassessment was made were not fully and truly disclosed to the
Chief Commissioner and, as a result, the tax liability was assessed at a lower
amount, or
(c) the reassessment is authorised to be made more than 5 years
after the initial assessment by another taxation law, or
(d) the reassessment
is made as a consequence of an application by a taxpayer, being an application
made within 5 years after the initial assessment of the liability, and the
reassessment reduces the tax liability.
(4) The initial assessment of a tax
liability remains the initial assessment of the liability for the purposes of
this Act even if it is withdrawn under section 13.
