(a) The limitation provided by § 111.201 of this code does not apply and the comptroller may assess a tax imposed by this title at any time if:
(1) with intent to evade the tax, the taxpayer files a false or fraudulent report;
(2) no report for the tax has been filed; or
(3) information contained in the report of the tax contains a gross error.
(b) In this section, “gross” error means that, after correction of the error, the amount of tax due and payable exceeds the amount initially reported by at least 25 percent.