53Summary award of penalties
(1)Any penalty incurred by any person for a failure to comply with a notice under section 51 above, or incurred by any person under section 52 above, may be awarded summarily by the Commissioners notwithstanding that no proceedings for its recovery have been commenced, and accordingly section 98(3) of this Act shall not apply to any penalty so awarded.
(2)An appeal shall lie to the High Court or, in Scotland, the Court of Session as the Court of Exchequer in Scotland, from the award of any penalty under this section, and on any such appeal the court may either confirm or reverse the decision of the Commissioners or reduce or increase the sum awarded.
(3)Any penalty awarded by virtue of this section shall for all purposes be treated as if it were tax charged in an assessment and due and payable.