82. Revision by the Commissioner.

The Commissioner may, on his own motion, call for and examine the record of any proceedings under this Act and if he considers that any order passed therein by any officer other than the Appellate Authority and the Appellate Tribunal, is erroneous in so far as it is prejudicial to the interest of the 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 section after the expiry of five years from the date of such order.