Extended limitation and suppression fail where classification, returns, invoices, and supporting naval-use evidence were disclosed.

Extended limitation cannot be invoked where the assessee had disclosed the classification in advance, filed monthly returns and invoices, and produced a certificate supporting use of the goods on board a naval ship. On those facts, the material relevant to exemption was not concealed, so suppression with intent to evade duty was not established. The demand raised beyond the normal limitation period was therefore time barred.

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Issues: Whether the extended period of limitation could be invoked on the allegation of suppression with intent to evade duty, where the assessee had filed classification declarations, monthly returns and invoices, and had produced a certificate regarding use on board a naval ship.

Analysis: The assessee had declared the classification in advance and had disclosed the clearances through monthly returns and invoices. The competent authority's certificate supported the claim that the goods were meant for use on board a naval ship. On these facts, the material necessary for availing the exemption was not concealed, and the allegation of suppression with intent to evade duty was not made out.

Conclusion: The extended period of limitation was not invocable, and the demand beyond the normal period was rightly held to be time barred. The appeal was dismissed.

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