72. Recovery of tax exempted

Notwithstanding any other provisions of this Part, where it appears to the

Collector that -

fa} any amount of exempted income of an international trading company;

or

{b) any dividend exempted in the hands of any shareholder, ought not to have been exempted by reason of a direction made under section 66

or the revocation under section 114 of the certificate issued under section 64 to the company, the Collector may subject to section 62 of the Income Tax Act

make such assessment or additional assessment upon the company or any such shareholder as may appear to be necessary in order to recover such tax as may have been exempted under this Part; or 1348