(1) If any question is raised by a dealer in respect of the rate of tax on any goods, the Commissioner shall, within six months from the date of receipt of the application made by the dealer for this purpose in the prescribed manner and on payment of such fee as may be prescribed, make an order determining the rate of tax on such goods in accordance with such procedure as may be prescribed.

(2) The Commissioner, if the circumstances so warrant, shall have the power to review any order passed under this section and pass such order as he deemed necessary .

Provided that,-

(i) no review of an earlier order shall be made unless a reasonable opportunity of being heard is given to the dealer who is likely to be adversely affected by the review, and

(ii) the Commissioner shall not reduce the rate of tax in review.

(3) Any order passed by the Commissioner under sub-section (1) and (2) shall have a prospective effect and shall be binding on the authorities referred to in Section 3 in all proceedings under this Act except appeals.