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Section 88

Finality of assessment. 

(1) Where, in relation to an assessment-
(a) no notice of objection has been given; or
(b) a notice of objection has been given and-
(i) the assessment has been amended under section 85 (2); or
(ii) a notice has been served under section 85(3) but no appeal has been brought against it; or
(iii) the assessment has been finally determined on appeal,

the assessment as made, or so amended, or determined on appeal, as the case may be, shall be final and conclusive for the purposes of this Act.

(2) Nothing in this section shall prevent the Commissioner from making an additional assessment for a year of income which does not involve reopening a matter which has been determined on appeal for that year of income; but where fraud or gross or wilful neglect has been committed by or on behalf of a person in connection with or in relation to tax for a year of income, the Commissioner may make an additional assessment on that person for that year of income notwithstanding that it involves reopening a matter which has been determined on appeal.

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