Extended limitation period fails without suppression or misstatement, and the duty demand is time-barred.

Extended period of limitation cannot sustain a duty demand absent evidence of suppression, misstatement, or other mala fide intent by the assessee. Where the manufacturing process and the likely emergence of blanketing in running length were matters the revenue was expected to know, invocation of the longer limitation period was unsustainable. The demand was therefore set aside as time-barred in favour of the assessee.

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Issues: Whether the demand of duty could be sustained by invoking the extended period of limitation in the absence of evidence of suppression or misstatement by the assessee.

Analysis: The appeal was disposed of on limitation. The record did not show any mala fide suppression or misstatement on the part of the assessee. The nature of the manufacturing activity was such that blanketing in running length would ordinarily come into existence, and the revenue was expected to be aware of that position. In the absence of evidence showing any mala fide intention, invocation of the longer period of limitation was held unsustainable.

Conclusion: The demand was set aside as time-barred, in favour of the assessee.

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