(1) In this section -
'claim' means a claim that gives rise to either or both a repayment of tax and a payment of interest payable in respect of such a repayment and includes part of such a claim;
'liability' means any tax due and payable which is unpaid and includes any tax estimated to be due and payable;
'overpayment' means a payment or remittance (including part of such a payment or remittance) which is in excess of the amount of the liability against which it is credited.
(2) Where the Collector-General is satisfied that a person has not complied with the obligations imposed on the person in relation to either or both -
(a) the payment of tax that is due and payable, and
(b) the delivery of returns required to be made,
then the Collector-General may, in a case where a repayment is due to the person in respect of a claim or overpayment -
(i) where paragraph (a) applies, or where paragraphs (a) and (b) apply, instead of making the repayment, set the amount of the repayment against a
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