11(1)Where a person becomes liable to an electronic sales suppression penalty—
(a)HMRC may assess the penalty, and
(b)if they do so, HMRC must notify the person.
(2)No electronic sales suppression penalty may be notified under sub-paragraph (1)(b) later than the end of the period of two years beginning with the day on which evidence of facts, sufficient in the opinion of HMRC to indicate liability to the penalty, comes to HMRC’s knowledge.