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22.—(1) Where–
(a)any relief or exemption from tax given in respect of income or gains under a plan is found not to be due or to be excessive, or
(b)where the full amount of tax in respect of the income or gains under a plan has not otherwise been fully accounted for and paid to the Board by or on behalf of the plan investor,
an assessment to tax may be made by the Board in the amount or further amount which in their opinion ought to be charged.
(2) An assessment to which paragraph (1) refers may be made on the plan manager or on the plan investor.
(3) If the assessment is made to recover tax in respect of income (including any amount in respect of a tax credit) under a plan it shall be made under Case VI of Schedule D.
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