Section 23. Revision by the Commissioner

The Commissioner may call for and examine the record of any proceedings under this Act, and if he considers that any order passed therein by the prescribed authority or any authority under section 9 of the Act, is erroneous or prejudicial to the interest of State revenue, he may, after having made or after having caused to be made such inquiry as he considers necessary, and after having accorded an opportunity of hearing to such person, shall pass appropriate orders : Provided that powers of revision under this section shall not be exercised by the Commissioner after the expiry of five years from the date of the order sought to be revised.