Objections lodged out of time
87 Objections lodged out of time
The Minister has a discretion to permit a person to lodge an objection after the end of the 60-day period but not to do so later than 12 months after—
in the case of an objection to an assessment—the date of service of the assessment on the taxpayer; or
in the case of an objection to some other decision—the date on which the taxpayer was notified of the decision.
The person seeking to so lodge the objection must state fully and in detail in the notice of objection the circumstances concerning and the reasons for the failure to lodge the objection within the 60-day period.
A failure or refusal of the Minister to grant permission under subsection (1) is a non-reviewable decision.
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