(1) Subject to section 102, where in relation to an assessment made on any person for any year of income, the Comptroller is of the opinion that—
(a) the tax charged is less than the amount which should have been charged;
(b) any assessed loss is greater than the amount at which it should have been assessed; or
(c) a refund was made in excess of the amount which should be refunded,
he or she shall make an additional assessment accordingly.
(2) Where, on the determination of an appeal made under Part 11, the appeal commissioners or any subsequent appellate tribunal increase an assessment, the Comptroller shall increase the assessment accordingly, without limit as to time.