(1)  If a person has obtained, or would but for this Division obtain, a tax benefit from entering into or carrying out a scheme of a kind referred to in section 113B(1) , or part of such a scheme, the Commissioner may –

(a) in making an assessment of tax liability under section 18 , include as part of the person's tax liability the amount of the tax benefit obtained or that would be obtained; or

(b) reassess the person's tax liability under section 19 so that the person's tax liability includes the amount of the tax benefit obtained.

(2)  If the Commissioner takes action under subsection (1) , the Commissioner must notify the person, in writing, that he or she has done so and his or her reasons for doing so.