Section 11. Petition for Reassessment of Certain Assessments; Notice.--Any vendor against whom an additional assessment or estimated additional assessment shall be made by the department may petition for a reassessment. Notice of an intention to file such a petition or to appear and be heard shall be given to the department prior to the time the amount becomes due and payable, to wit, within ten days after notice of such assessment is given to the vendor as provided in this act. Petitions for reassessment may be filed with the department on or before the date designated in the notice of such assessment when hearings on such petitions will be held. The department shall hold such hearings in each county as may be necessary to hear and determine petitions for reassessment. Such hearings shall be held at the time and place indicated in the notice of such assessment given to the vendor. All petitions filed with the department shall set forth specifically and in detail the grounds upon which it is claimed such assessment is erroneous or unlawful, and shall be accompanied by an affidavit, under oath or affirmation, certifying to the correctness of the facts stated therein. If no petition for reassessment is filed with the department, the vendor may, in lieu thereof, appear at the hearing and present his petition orally, in which event all testimony or statements of facts shall be made under oath or affirmation.
If the vendor is still dissatisfied with the finding of the department, he shall have the right to appeal to the court of common pleas of the proper county within twenty days after notice of the determination of the petition is given to him by the department. If any vendor shall fail to give due notice of an intention to petition for reassessment or to file a petition for reassessment after due notice of his intention to do so, or to appeal to the court of common pleas, within the time and in the manner herein set forth, the right to do so shall be forever barred, and any such vendor so failing shall not thereafter be permitted, in a suit for the recovery of such tax, to set up any ground of defense which might have been determined either by the department or the court of common pleas as aforesaid: Provided, That nothing contained in this section shall be construed to grant to any such vendor the right to petition for reassessment or to appeal from estimated assessments made by the department for neglect or refusal to make a return within the time prescribed by this act: And provided further, That every appeal to the court of common pleas under this section shall specify all the objections to the assessment, and any objection not specified in the appeal shall not be considered by the court. In all cases of petitions for reassessment and appeals, the burden of proof shall be on the petitioner or appellant, as the case may be.