(1) The Commissioner may, on his own motion, call for and examine the records of any proceedings under this Act and if he considers that any order passed by any authority subordinate to him, is erroneous in so far as it is prejudicial to the interest of revenue, may, after giving the dealer a reasonable opportunity of being heard, pass such order as he deems fit:

Provided that the Commissioner shall not pass any order under this sub-section after the expiry of eight years from the end of the year in which the order sought to be revised was made.

(2) In the case of any order passed by a person appointed to assist the Commissioner under sub-section (1) of section 3, not being an order to which sub-section (1) applies, and not being an order against which an appeal under section 79 has been filed or an order in respect of which the time allowed for appeal under section 79 has not expired, the Commissioner may, either of his own motion or on an application made in the prescribed manner by the dealer or person affected by such order, call for the record of any proceeding under this Act in which any such order has been passed and may make such enquiry or cause such enquiry to be made and subject to the provisions of this Act, pass such orders thereon, not being an order prejudicial to the dealer or person to whom the order relates as he thinks fit.

(2A) An application by a dealer or person shall not be entertained by the Commissioner unless such application is accompanied by satisfactory proof of payment of minimum twenty five percent of the disputed tax, penalty, if any, imposed and the interest accrued thereon, if any :

Provided that the Commissioner may, if it thinks fit, for reasons to be recorded in writing and subject to furnishing of such security as Commissioner may deem fit, admit an application with part payment or without any payment of the disputed amount of tax including penalty, if any, required under this sub-section with a view to mitigate undue hardship which is likely to be caused to the dealer or person if the payment of such disputed amount is insisted on.

Provided further that the Commissioner may stay the recovery of the full or part of the balance amount of tax, interest and penalty, till disposal of the application.

(3) Every application for revision under sub-section (2) shall be filed within ninety days of the date on which the order is sought to be revised against is communicated to the dealer or the person:

Provided that the Commissioner may admit an application for revision after the expiry of ninety days if he is satisfied that the dealer or the person had sufficient reasons for not filing the appeal within the aforesaid time, if it is within a further period of one hundred eighty days.

(4)(a) When a Prescribed Authority is aggrieved by any order passed by the Appellate Authority, he may file a revision petition within ninety days from the date of receipt of such order.

(b) When a revision petition is filed by a Prescribed Authority, the Commissioner may, after examination of the order of the Appellate Authority, and the records of any proceeding under the Act to which the order of the Appellate Authority relates and after making an enquiry, or causing an enquiry to be made, as he may deem necessary, pass any order reversing, modifying or upholding the order of the Appellate Authority:

Provided that Commissioner shall not pass any order prejudicial to the dealer or the person to whom the order relates without giving him a reasonable opportunity or being heard.