86. Recovery of tax exempted

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

Collector that-

{a) any amount exempted income of a company; or

any dividend exempted in the hands of any shareholder, ought not to have been exempted by reason of the revocation under section 114 of the certificate issued under section 80 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