47I. Power of the Commission to re-open proceedings.-

If the Commission is, for reasons to be recorded in writing, of the opinion that for the proper disposal of the case pending before it, it is essential to reopen any proceedings connected with the case but which have been completed under this Act by any officer of Sales Tax before the application under section 47D was made, it may, with the concurrence of the applicant, re-open such proceedings and pass such order thereon as it thinks fit, as if the case in relation to which the application for settlement had been made by the applicant under that section covered such proceedings as well:

Provided that no proceedings shall be re-opened by the Commission under this section if the period between the end of the tax period to which such proceedings relate and the date of application for settlement under section 47D exceeds five years.