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Assessment of tax.
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16.—(1) The Commissioners may make an assessment of tax payable upon the net market value of the property comprised in the taxable wealth of an assessable person on the relevant valuation date on the basis of the return delivered pursuant to section 15.
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(2) An assessment of tax may be reviewed by the Commissioners at any time and, where any amendment of an assessment is necessary as a result of the review, whether in respect of the taxable wealth already assessed to tax or in respect of any additional taxable wealth, the Commissioners may—
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(a) to the best of their knowledge, information and belief, make an amended assessment of the tax due and payable upon the net market value of the taxable wealth of the assessable person concerned, or any part thereof, or
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(b) require any accountable person to deliver to them, within such time, not being less than 30 days, as may be specified in the requirement, an additional return on a form provided by the Commissioners of all the property (or any part thereof) comprised in the taxable wealth of the assessable person together with a statement verifying such particulars and also such evidence, statements and documents as they require relating to any property therein, or to any property which they have reason to believe to form part of the taxable wealth of the assessable person, and may make an amended assessment of the amount of tax due and payable on the basis of the additional return:
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Provided that, where any accountable person who has delivered a return or additional return is aware or becomes aware at any time that the return or additional return is defective in a material respect by reason of anything contained in or omitted from it, he shall, without application from the Commissioners and within three months of so becoming aware, deliver to them an additional return to enable an amended assessment to be made.
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(3) In any case in which—
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(a) a return is not delivered by an accountable person to the Commissioners within three months after the relevant valuation date,
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(b) an additional return required by or under subsection (2) (b) to be delivered is not delivered within the appropriate time specified in the said subsection (2) (b), or
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(c) a return or an additional return is unsatisfactory to them,
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it shall be lawful for the Commissioners to make an assessment of tax payable upon the net market value of the property comprised in the taxable wealth or any part thereof on the relevant valuation date of such amount or further amount as, to the best of their knowledge, information and belief, ought to be charged, levied and paid:
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Provided that the Commissioners may withdraw an assessment made under this subsection and make an assessment of the amount of tax payable on the basis of a return or an additional return which, in their opinion, represents reasonable compliance with their requirements and which is delivered to the Commissioners within 30 days after the date of the assessment made by the Commissioners in pursuance of this subsection.
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(4) The making of an amended assessment shall not prejudice the right of the Commissioners to make further amended assessments of the amount of tax payable or to require delivery from the accountable person concerned of further additional returns, and the provisions of this section shall apply to such returns.
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(5) Nothing done or suffered by reason or in consequence of any assessment made under this section shall prejudice the determination of any issue which may arise in the course of a further assessment or assessments.
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(6) The Commissioners may, if they are satisfied that it is necessary to do so, extend any time limit specified in section 14 or 15 or in this section.
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(7) Any amount of tax assessed under this section shall be due and payable to the Commissioners.
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