Where:
(a) an employer has not furnished a return in respect of a year of tax; and
(b) the Commissioner is of the opinion that the employer is liable to pay tax in respect of that year;
the Commissioner may, whether during that year or after the end of that year, make an assessment of:
(c) the fringe benefits taxable amount of the employer of the year of tax; and
(d) the amount of tax payable on that fringe benefits taxable amount.