23(1)Where too little tax has been paid in respect of a chargeable transfer the tax underpaid shall be payable with interest thereon under paragraph 19 above, whether or not the amount that has been paid was that stated as payable in a notice under paragraph 6 above ; but subject to the following provisions of this paragraph and to paragraph 25 below.
(2)Where tax attributable to the value of any property is paid in accordance with an account duly delivered to the Board under this Schedule and the payment is made and accepted in full satisfaction of the tax so attributable, no proceedings shall be brought for the recovery of any additional tax so attributable after the expiration of the period of six years beginning with the later of the following dates, namely.—
(a)the date on which the payment (or in the case of tax paid by instalments the last payment) was made and accepted ; and
(b)the date on which the tax or the last instalment became due;
and on the expiration of that period any liability for the additional tax and any Inland Revenue charge for that tax shall be extinguished.
(3)In any case of fraud, wilful default or neglect by a person liable for the tax, the period mentioned in sub-paragraph (2) above shall be the period of six years beginning when the fraud, default or neglect comes to the knowledge of the Board.
24(1)If it is proved to the satisfaction of the Board that too much tax has been paid on the value transferred by a chargeable transfer or on so much of that value as is attributable to any property, the Board shall repay the excess unless the claim for repayment was made more than six years after the date on which the payment or last payment of the tax was made.
(2)References in this paragraph to tax include references to interest on tax.