Automatic mitigation and increase of penalties
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....ll be refunded. (2) If - (a) a person is liable to pay a penalty under 1[***] sub-section (12) of section 86 of this Act; and (b) the person voluntarily discloses to the Commissioner in writing the existence of the tax deficiency before the Commissioner informs the person that an audit of the person's tax obligations is to be carried out; the amount of the penalty otherwise due shall be red....
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....he Commissioner under section 84 of this Act or a ruling issued by the Commissioner under section 85 of this Act; the amount of the penalty otherwise due shall be reduced to nil. (5) Where - (a) penalty under this Act has been assessed; (b) the penalty has not been remitted in full after objection; and (c) the person is subsequently assessed to a further penalty in respect of the same or ....