Assessment and penalty in case of evasion by unregistered persons

If upon information which has come into his possession, the Commissioner is satisfied that any person while being liable to pay tax under this Act in respect of any period, has nevertheless willfully failed to apply for registration and to pay the tax, he shall, after giving the person a reasonable opportunity of being heard, assess, to the best of his judgment, the amount of tax, if any, due from him in respect of such period and all subsequent period and the Commissioner may also direct that in addition to the amount so assessed a sum not exceeding that amount shall be recovered from the defaulter ]by way of penalty.