[100D Penalty proceedings before court]

[100D  Penalty proceedings before court]

[(1)     Where in the opinion of the Board the liability of any person for a penalty arises by reason of the fraud of that or any other person, proceedings for the penalty may be instituted before the High Court or, in Scotland, the Court of Session as the Court of Exchequer in Scotland.

(2)     Proceedings under this section which

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