69(1)Where a senior tracking officer, or the purchaser, becomes liable for a penalty under paragraph 68—
(a)Her Majesty’s Revenue and Customs may assess the penalty, and
(b)if they do so, they must notify the person liable for the penalty.
(2)An assessment of a penalty under this Part for a failure in respect of a tracking period may not be made—
(a)more than 6 months after the failure first comes to the attention of an officer of Revenue and Customs, or
(b)more than 6 years after the filing date for the purchaser’s tax return for the tracking period (see paragraph 14 of Schedule 18 to FA 1998).
(3)See paragraph 94 for provision about appeals against a penalty under paragraph 68.