Extended limitation cannot rest on alleged suppression where the record shows full disclosure and no factual perversity.

Extended period of limitation could not be invoked where the record showed no suppression of facts or misstatement by the assessee. The Tribunal found that removal of goods for job work required permission, the department was aware of the removals, and the manufacturing process had been disclosed. That finding was treated as factual, and no perversity in the Tribunal's conclusion was shown. On that basis, the extended limitation period was held inapplicable and no substantial question of law arose.

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Issues: Whether the extended period of limitation could be invoked on the basis of alleged suppression of facts and misstatement by the assessee.

Analysis: The Tribunal's finding that there was no suppression of facts or misstatement was based on the record. It noted that removal of goods for job work required permission, that the department was aware of the removal, and that the manufacturing process was disclosed. The finding was factual and no perversity in that conclusion was shown.

Conclusion: The extended period of limitation was not invocable, and no substantial question of law arose.

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