20   Windfalls—refusal of refund

The Chief Commissioner may refuse to make a refund to a taxpayer if:

(a)  the relevant taxation law provides for the passing on of the tax to another person, and

(b)  the tax sought to be refunded has been passed on to another person, and

(c)  the Chief Commissioner is not satisfied that appropriate arrangements have been made to pass the tax sought to be refunded on to that other person.