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....ommissioner may, of his own motion or upon information received by him, call for the record of such order and examine whether -            (a) any turnover of sales has not been brought to tax  or has been brought to tax at lower rate, or has been incorrectly classified, or any claim is incorrectly granted or that the liability to tax ....

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....poses aforesaid.            (b) Notwithstanding anything contained to the contrary in section 34, no order under this section shall be passed after the expiry of four years from the end of the year in which the order passed by the subordinate officer has been served on the dealer.            (....

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....on or the report or the information received by him and the said appellate authority including the Tribunal shall thereupon, after giving the dealer a reasonable opportunity of being heard, pass an order to the best of its judgment, where necessary.        (3) If the Commissioner has initiated any proceeding before an appropriate forum against an issue which is dec....