Recovery of erroneous refund requires a demand under Section 11A within limitation rather than relying on review. An order under Section 35E(2) does not by itself recover an erroneously granted refund; recovery must be effected by issuing a show cause notice and demand under Section 11A within the statutory limitation period from the date of refund. Because the appeal period under Section 35E(2) exceeds the limitation for Section 11A demands, authorities should proceed to raise timely demands under Section 11A (within six months) rather than relying on the review/appeal route.