Limitation for excise demand follows the statutory monthly return date, not an administrative concession for consolidated filing.

An administrative trade notice allowing consolidated filing could not override the statutory requirement to file monthly returns under Rule 173G. For limitation under Section 11A, the relevant date was the date prescribed by the rules for filing the monthly return for the period concerned, not the date of the consolidated return. As the monthly return was filed on 10-1-1995 and the demand notice was issued within six months of that date, the notice was within time and the limitation objection failed.

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Issues: Whether the demand notice was time-barred on the footing that the relevant date for limitation was the date of filing of the consolidated return, instead of the date prescribed for monthly returns under the excise rules.

Analysis: The liability to file returns was governed by the requirement of monthly returns under Rule 173G. The trade notice permitting consolidated filing was only an administrative concession and could not override the statutory rule. For the purpose of Section 11A, the relevant date had to be computed with reference to the date on which the monthly return for the concerned period was required to be filed. Since that return was filed on 10-1-1995, the notice issued within six months from that date was within limitation.

Conclusion: The limitation objection failed and the demand notice was held to be within time.

Ratio Decidendi: An administrative concession cannot displace the statutory requirement of monthly returns, and the relevant date for limitation under Section 11A is to be determined with reference to the date prescribed by the rules for filing such return.

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