(5)The order shall not be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct or collect the whole or any part of the tax from any person––(a)after six years from the end of the tax year in which tax was deductible or collectible; or(b)after two years from the end of the tax year in which the correction statement is delivered under section 397(3)(f), whichever is later.
