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6.—(1) Where—
(a)any relief or exemption from tax given in respect of income or gains under an account is found not to be due or to be excessive, or
(b)the full amount of tax in respect of the income or gains under an account has not otherwise been fully accounted for and paid to the Commissioners on behalf of the account holder,
an assessment to tax may be made by the Commissioners 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 account provider or on the account holder.
(3) If the assessment is made to recover tax in respect of income under an account it shall be made under section 369 of ITTOIA 2005.
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