Section 9 (3)
substitute
(3) The commissioner must not make a reassessment of a tax liability—
(a) more than 5 years after the initial assessment of the liability, unless—
(i) the purpose of the reassessment is to give effect to a decision on an objection or appeal as to the initial assessment; or
(ii) at the time the initial assessment or a reassessment was made, all the facts and circumstances affecting the liability under the relevant tax law of the person in relation to whom the assessment or reassessment was made were not fully and truly disclosed to the commissioner; and
(b) for an excluded organisation in relation to which a beneficial organisation determination does not apply—if the purpose of the reassessment is to give effect to a decision that the organisation has a tax liability, or has no tax liability, under a relevant provision.