13.1 The adjudication order passed by the officers subordinate to the Commissioner of Service Tax could be revised by the Commissioner after causing inquiry as he deems fit, in terms of section 84 of the Act. The limitation period for issuing such reversionary order is two years from the date on which original order is passed. However, the issue against which appeal has been filed by the service taxpayer before Commissioner (Appeal) cannot be revised. Thus if an order deals with several issues and party files appeal only in respect of few issues, the commissioner can pass revisionary order in respect of remaining issues against which appeal has not been filed by the party.

13.2     Further, before revising any order, an opportunity for hearing is to be given to service taxpayer to comply with the principle of natural justice.