law: Expenditure-Tax Act, 1987 
  21. Revision of orders by the Commissioner 
  (1) The Commissioner may, either of his own
  
  motion or on application by the assessee for revision, call for the record of a
  
  proceeding under this Act which has been taken by the 16[Assessing]
  
  Officer subordinate to him 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 he thinks fit.
  (2) No order which is prejudicial to the
  
  assessee shall be passed under this section unless the assessee has been given
  
  an opportunity of being heard.
  (3) No order under this section shall be passed
  
  by the Commissioner, if an appeal against the notice of demand issued by the 16[Assessing]
  
  Officer under section 20 is pending before the Commissioner (Appeals).
  (4) No order under this section shall be
  
  passed after the expiry of two years from the end of the financial year in
  
  which the order sought to be reviewed has been passed.
   15  [(6) On every application by an assessee for
  
  revision under this sub-section, made on or after the lst day of October, 1998,
  
  an order shall be passed within one year from the end of the financial year in
  
  which such application is made by the assessee for revision.
  Explanation.- In computing the
  
  period of limitation for the purposes of this sub-section, the time taken in giving
  
  an opportunity to the assessee to be re-heard under the proviso to section 24
  
  and any period during which any proceeding under this section is stayed by an
  
  order or injunction of any court shall be excluded.
  (7) Notwithstanding anything contained in
  
  sub-section (6), an order in revision under that sub-section may be passed at
  
  any time in consequence of or to give effect to any finding or direction
  
  contained in an order of the Appellate Tribunal, High Court or the Supreme
  
  Court.]