Limitation for duty demand fails where imported goods were duly declared and no suppression with intent to evade duty was shown.

The demand was treated as time-barred because suppression of facts with intent to evade duty was not established. The goods were imported and described in the import documents as betel nuts, the declaration matched the invoices, and the goods had already been assessed by the proper officer on that basis. As the show-cause notice was issued after the relevant limitation period and no wilful suppression was shown, the extended limitation period was unavailable, and the Revenue's challenge failed.

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Issues: Whether the demand was barred by limitation in the absence of suppression of facts with intent to evade duty.

Analysis: The goods were imported and described in the import documents as betel nuts. The show-cause notice was issued after the period relied upon by the Revenue. Since the declaration matched the description in the invoices and the goods had been assessed accordingly by the proper officer, the required suppression with intent to evade duty was not established.

Conclusion: The demand was held to be time-barred, and the Revenue's appeal failed.

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