An election referred to in paragraph 94D(1)(d) in relation to a limited partnership and in relation to a year of income has no effect unless:
(a) the partnership passes the continuity of ownership test set out in section 94G; and
(b) the election is made:
(i) within 6 months after the end of the later of the following years of income:
(A) the year of income to which the election relates;
(B) the year of income in which the Taxation Laws Amendment Act (No. 6) 1992 received the Royal Assent; or
(ii) within such further period as the Commissioner allows.