(1)  The Commissioner may make one or more reassessments of a tax liability of a taxpayer.

(2)  The Commissioner may –

(a) make a reassessment of a tax liability of a taxpayer after an amount previously assessed as being payable by the taxpayer has been paid; or

(b) make a reassessment of a tax liability under which the taxpayer is assessed as having liabilities that are additional to, or greater than, those under the previous assessment.

(3)  The Commissioner must not make a reassessment of a tax liability more than 5 years after the initial assessment of the liability unless –

(a) the reassessment is to adjust tax to give effect to a decision on an objection, review or appeal 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 tax 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 Commissioner; or

(c) the initial assessment was an assessment by way of estimate under section 21(2) .

(4)  The time limited by subsection (3) applies even if the initial assessment is withdrawn.