Extended limitation cannot be invoked without suppression when the manufacturing process was fully disclosed to the department.

The extended period of limitation was unavailable where the manufacturer had filed a declaration disclosing the cutting and slitting process applied to duty-paid jumbo rolls and sought exemption on that basis. As the department was informed of the nature of the activity, there was no suppression of material facts to justify invoking the extended limitation period. The demand for duty could not therefore be sustained on that ground.

---

---

Issues: Whether the extended period of limitation could be invoked for demanding duty on the cut and slit thermal paper cleared by the appellant.

Analysis: The appellant had filed a declaration with the department stating the manufacturing process and claiming exemption on the basis of slitting and cutting of duty-paid jumbo rolls into smaller rolls. On the facts disclosed, the department was informed of the process undertaken and could not sustain an allegation that the appellant had suppressed the nature of the activity so as to justify invocation of the extended period.

Conclusion: The extended period of limitation was not available to the department, and the demand could not be sustained on that basis.

---