(1) The Commissioner of State Tax may suo motu call for and examine any order passed or proceeding recorded under this Act by any officer or authority subordinate to it which in his opinion is prejudicial to revenue and may make such enquiry or cause such enquiry to be made and subject to the provisions of this Act may pass such order thereon as it thinks fit.

(2) The Commissioner of State Tax shall not pass any order under Sub-section (1) if-

(a) the time for appeal against that order has not expired;

(b) the order has been made the subject matter of an appeal to the Appellate Authority or Appellate Tribunal or of a revision in the High Court; or

(c) more than four years have expired after the passing of the order referred to therein.

(2A) Notwithstanding anything contained is Sub-section (2), the Commissioner of State Tax may pass an order under Sub-section (1) on any point which has not been decided in an appeal or revision referred to in Clause (b) of sub-section (2), before the expiry of a period of one year from the date of the order in such appeal or revision or before the expiry of a period of four years referred in Clause (c) of that Sub-section, whichever is later.

(3) No order under this section adversely affecting a person shall be passed unless that person has had a reasonable opportunity of being heard.