Alteration of assessment of penalty
39(1)After notification of an assessment has been given to a person under paragraph 38(2), the assessment may not be altered except in accordance with this paragraph or on appeal.
(2)A supplementary assessment may be made in respect of a penalty if an earlier assessment operated by reference to an underestimate of the value of the counteracted advantage.
(3)An assessment may be revised as necessary if operated by reference to an overestimate of the value of the counteracted advantage.