Modification of tax liability

Review.—(1) The Commissioner may, on his own motion, call for the record of the proceedings in which an order was passed by any person appointed to assist him, and if he considers that any order passed therein is erroneous in so far as it is prejudicial to the interests of revenue, he may, after giving the dealer an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. (2) No order shall be made under sub-section (1) after the expiry of a period of three years from the end of the year in which the order sought to be reviewed was passed.