- The Commissioner may on his own motion at any time within three years from the date of passing of any order by the Luxury Tax Officer or within two years from the date of passing of any order by the Assistant Commissioner, as the case may be, call for records of the proceeding in which such order was passed and if he consider that any order passed therein is erroneous in so far as it is prejudicial to the interest of the revenue he may after giving the stockist an opportunity of being heard and after making or causing to be made such enquiry as he deems necessary revise any such order :Provided that the Commissioner shall not revise any order under this rule -(1)where an appeal against the order is pending before the appellate authority under Section 15, or(2)where time-limit for filing an appeal under Section 15 has not expired.
