33.
(1)Where any registered person has furnished a return under subsection (1 ) of section 21 in respect of a taxable period or has been assessed for tax in respect of any period, it shall not be lawful for the Assessor where an assessment-
| | (a)has not been made to make an assessment, or | | |
| | (b)has been made to make an additional assessment after the expiration of three years from the end of the taxable period in respect of which the return is furnished on the assessment was made as the case may be . | | |
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(2) Notwithstanding the provisions of subsection (1) where the Assessor is of opinion that a person has wilfully or fraudulently failed to make a full and true disclosure of all the material facts necessary to determine the amount of tax payable by him for any taxable period, it shall be lawful for the Assessor where an assessment -
| | (a)has not been made, to make an assessment, or | | |
| | (b)has been made to make an additional assessment, | | |
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