The purpose of determining the period during which the Authority can make the final assessment without extending in time beyond that period is to desire the stability of the financial and legal positions of taxpayers and the Authority.

The Authority's right to exercise what was guaranteed thereto by the Law in conducting the final assessment shall be after requesting inquiries and information from the taxpayer to reach the final assessment in its final form within the five years that the Law specified its beginning by the end of the period prescribed for submitting the return.

It is not valid under the provisions of the Law for the Authority to exceed the statutory period without notifying the taxpayer of the amended assessment.