Additional assessment

(1) Where it appears to the Commissioner that any person or entity liable to pay surcharge under this Part has not been assessed or has been assessed at a lower amount than that which ought to have been charged, the Commissioner may, at any time within the year of assessment or within six years after the expiration thereof, assess such person or entity at such additional amount as, according to his or her judgment ought to have been charged, and the provisions of this Act as to notice of assessment, appeal and other proceedings shall apply to such assessment or additional assessment and to the surcharge charged thereunder. (2) The Commissioner may, if satisfied that the act of omission or commission amounts to fraud or contrivance, or gross and willful neglect on the part of the person or entity assessed, or to be assessed, charge such person or entity in respect of such additional surcharge and penalty an amount equal to double the amount of the surcharge and penalty payable on the excess. (3) The provisions relating to assessments, review, objections, appeals, collections and the recovery of income tax contained in Part I of this Act shall apply mutatis mutandis to assessments, review, objections, appeals, collections and the recovery of surcharge under this Part.