Extended limitation under central excise fails where no wilful suppression is shown and exemption changes were temporary.

The extended limitation period under the proviso to Section 11A of the Central Excise Act, 1944 was not available because the notice and order did not establish wilful suppression of facts with intent to evade duty. The demand arose during a brief interval when exemption was withdrawn and then quickly restored, and the non-payment was attributed to ignorance of that temporary change. The long-standing exemption regime supported the assessee's bona fides, so the duty demand was held time-barred.

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Issues: Whether the show cause notice invoking the extended period under the proviso to Section 11A of the Central Excise Act, 1944 was justified and whether the duty demand was time-barred.

Analysis: The demand related to a short interim period when exemption from duty had been withdrawn and then restored shortly thereafter. No material was relied upon in the notice or the impugned order to establish wilful suppression of facts with intent to evade duty. The non-payment was found to be attributable to ignorance of the temporary withdrawal of exemption, and the long-standing exemption regime supported the bona fides of the assessee.

Conclusion: The invocation of the extended period was not justified and the demand was time-barred.

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