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Notwithstanding anything in this Part, where it appears to the Collector that any deduction under section 100 ought not to have been given to an eligible holding company by reason of any direction under subsection (8) of section 100 or the revocation under section 114 of a certificate issued to a technology company, the Collector may, subject to section 62 of the Income Tax Act, make such assessment or additional assessment upon the eligible holding company or any of its shareholders as may be necessary in order to recover any tax which should have been payable by the eligible holding company.