Extended limitation fails where price declarations were disclosed and approved, making suppression unproven and the demand time-barred.

Extended limitation could not be invoked where the price list for the impugned clearances had been filed and approved by the department and no suppression of facts was established. On those facts, the show-cause notice issued long after the relevant period was barred by limitation, so the demand was unsustainable without entering the valuation merits. Penalty also could not be imposed because the demand itself failed on limitation.

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Issues: Whether the demand was barred by limitation in the absence of suppression of facts where the price list had been filed and approved.

Analysis: The show-cause notice was issued long after the relevant period, while the price list for the impugned clearances had already been filed and approved by the competent authority. On these facts, the allegation of suppression was not sustainable. The demand was therefore examined only on limitation, without entering into the merits of valuation.

Conclusion: The show-cause notice was held to be barred by limitation, the demand was held unsustainable, and penalty was held not imposable.

Ratio Decidendi: The extended period of limitation cannot be invoked when the relevant price declaration was disclosed to and approved by the department and no suppression of facts is established.

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