If:
(a) the entity does not make a full and true disclosure to the Commissioner of the information necessary for a franking assessment for the entity for the balancing period; and
(b) in making the assessment, the Commissioner makes an under - assessment; and
(c) the Commissioner is not of the opinion that the under - assessment is due to fraud or evasion;
the Commissioner may amend the assessment at any time during the period of 6 years after the original franking assessment day.