Extended limitation cannot be invoked without suppression of facts, where full disclosure and departmental knowledge are found.

The extended period of limitation was held unavailable where the Tribunal found that all relevant facts had been disclosed by the assessee and were within the department's knowledge. That finding negatived any allegation of suppression of facts, and the Supreme Court treated it as a factual determination with no basis for interference. As a result, the department could not rely on extended limitation against the assessee, and the departmental appeals failed.

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Issues: Whether the department could invoke the extended period of limitation on the basis of alleged suppression of facts by the assessee.

Analysis: The Tribunal had examined the evidence and found that all relevant facts had been disclosed by the assessees and were within the knowledge of the department. On that basis, it held that there was no suppression of facts and that the extended period of limitation was not available. The Supreme Court treated this determination as a finding of fact and found no reason to interfere.

Conclusion: The extended period of limitation could not be invoked against the assessee, and the departmental appeals failed.

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