Section 51 — Assessment in event of fraud

(1)Despite section 49, where, in the Comptroller’s opinion, any form of fraud or wilful default has been committed by or on behalf of any person in connection with or in relation to any liability for MTT or DTT, the Comptroller may, for the purpose of making good any loss of MTT or DTT attributable to the fraud or wilful default, at any time make an assessment of the MTT or DTT that in the Comptroller’s judgment is payable.

(2)Section 49(3) and (5) to (8) applies in relation to an assessment under this section as it applies in relation to an assessment under section 49.