Limitation for ad valorem duty ran only after quantification was made clear, keeping the appeal within time.

Where an ad valorem duty order did not state the value of the goods, it did not by itself disclose the exact duty payable and required later clarification before liability could be computed with certainty. The later demand supplied the missing basis for quantification, so limitation could not run only from the original order. On that footing, the appeal before the Appellate Collector was held to be within time, and dismissal on limitation was incorrect.

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Issues: Whether the appeal before the Appellate Collector was within limitation when the original order demanded duty at the appropriate rate without stating the value on which the ad valorem levy was to be computed.

Analysis: The duty on molasses was leviable on an ad valorem basis, but the Assistant Collector's order did not state the value of the goods and therefore did not by itself disclose the exact quantum of duty payable. The later demand issued by the Superintendent supplied the missing basis for computing the levy. In these circumstances, the date relevant for limitation was not confined to the earlier order alone, because the original order needed clarification before the liability could be worked out with certainty.

Conclusion: The appeal before the Appellate Collector was within time, and the dismissal on limitation was incorrect.

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