1011. For the purposes of paragraph b of subsection 2 of section 1010, the Minister shall not, in computing the income of a taxpayer upon a reassessment or additional assessment made after the expiry of the time limits provided for in paragraphs a to a.2 of that subsection 2, include any amount other than an amount(a) that can reasonably be regarded as having been the subject of a waiver referred to in subparagraph ii of paragraph b of subsection 2 of section 1010, unless the taxpayer establishes otherwise, or
(b) in respect of which the failure to include it in computing income resulted from misrepresentation attributable to negligence or wilful default or from fraud, on the part of the taxpayer, in filing the fiscal return or in supplying information under this Part, unless the taxpayer establishes otherwise.