The general rule is that no assessment may be made more than 6
years after the effective date of the transaction to which it
relates but in cases of fraud or negligence this is extended to 21
years.
If the purchaser has died, assessments must be made within 3
years of the date of death and can only cover transactions within
the 6 years prior to death.
An assessment to recover excessive repayment of tax is not
out of time
Any objection to the making of an assessment on the grounds that the time limit for making it has expired can only be made on an appeal against the assessment.