Section 23
Income wrongly exempted, etc.
(1)
Notwithstanding any other provision of this Act, where it appears to the Collector that any income of the relevant company exempted under section 21 or any dividend exempted in the hands of a shareholder under section 22 ought not to have been exempted by reason of —
(a)
a direction under section 17 having been given with respect to a pioneer company after any income of the company has been exempted under section 21;
(b)
the cancellation of a pioneer certificate, he may, at any time within 6 years after the date of the direction or cancellation, make such additional assessments upon any person as appear to him to be necessary in order to counteract any benefit obtained from the exemption, or direct the relevant company to debit the exempt account with such amount as the circumstances required.
(2)
A direction given under subsection (1) shall, for the purposes of section 68 of the Income Tax Act, be deemed to be a notice of assessment.
Carry forward of loss incurred in tax relief period.