(1) If:
(a) a * corporate tax entity does not make a full and true disclosure to the Commissioner of the information necessary for a * franking assessment for the entity for an income year; and
(b) in making the assessment, the Commissioner makes an * under - assessment; and
(c) the Commissioner is not of the opinion that the under - assessment is due to fraud or evasion;
the Commissioner may amend the assessment at any time during the period of 6 years after the * original franking assessment day for the entity for the year.
(2) The Commissioner makes an under - assessment in a * franking assessment (the earlier assessment ) if, in amending the earlier assessment, the Commissioner would have to do one or more of the following for the amended assessment to be correct:
(a) reduce the * franking surplus (including to a nil balance);
(b) increase the * franking deficit (including from a nil balance);
(c) increase * franking tax payable.