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Issues: Whether the show cause notice issued in 1995 was barred by limitation where the demand was founded on statutory documents filed by the assessee, and whether the extended period under section 11A could be invoked.
Analysis: The demand was based on AR 3A and other statutory records already filed during the relevant period, which disclosed the discrepancy between the quantity despatched and the quantity re-warehoused. In such a situation, the department was required to proceed within the normal period of limitation, and the invocation of suppression for extending limitation was not justified.
Conclusion: The demand was held to be barred by limitation and the appeal was allowed on the time-bar issue.