Section 62(3) in The M.P. Vanijyik Kar Adhiniyam, 1994
(3)The Commissioner may on his own motion or on information received call for and examine the record of any proceeding under this Act if he considers that any order passed therein by any person appointed under Section 3 to assist him including any officer to whom he has delegated his powers under sub-section (1) in pursuance of the provisions of Section 46, is erroneous in so far as it is prejudicial to the interest of the revenue, he may after giving the dealer or person a reasonable opportunity of being heard, after making or causing to be made such enquiry as he deems necessary, pass such order thereon, within on calender year from the date of initiation of proceeding as the circumstances of the case justify, including an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment:Provided that no proceeding shall be initiated under this subsection after the expiry of [five calender years] [Substituted by Section 11 of MP Commercial Tax (Second Amendment) Act, 1997 (No. 33 of 1997), w.e.f. 1-9-1997.] from the date of the order sought to be revised :Provided further that the Commissioner shall not revise any order under this sub-section where a second appeal against such order is pending or such appeal has been decided on merits.
