673. Meaning of 'discovers'.

To 'discover' means simply to find out, and applies to the discovery of an error in law and an error in fact1. It does not mean 'ascertains by legal evidence'2 but 'comes to the conclusion from the examination he, the officer of Revenue and Customs, makes, and from any information he may choose to receive'3 or 'has reason to believe'4, or 'finds or satisfies himself'5, or 'honestly comes to the conclusion on the information before him'6.

Where, as a result of an erroneous view of the law, assessments are not made, the discovery of the error justifies additional assessments