78. Revision by Commissioner.-

The Commissioner may, on his own motion, call for and examine the record of any proceedings under this Act if he considers that any order passed therein by any officer including the first appellate authority, is erroneous in so far as it is prejudicial to the interest of the revenue, and after giving the assessee an opportunity of being heard, pass such orders as he deem fit: he may, if necessary, stay the operation of such order for such periods as he deems fit and after giving the assessee an opportunity of being heard and after making or causing to be made such enquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or canceling the assessment or directing a fresh assessment;

Provided that the Commissioner shall not pass any order under this Section after the expiry of five years from the date of such order.