Extended limitation in job-work valuation disputes fails where suppression is not established consignment-wise and value correlation is uncertain.

Extended limitation under the proviso to section 11A could not be invoked for the job-work duty demand because the materials relied on did not establish suppression of facts with precision. The show cause annexures were only party-wise and period-wise, not job-order-wise, so they did not support a consignment-specific finding of concealment. The items cited for valuation, including bank charges, letter of credit charges, to-bond and de-bond charges, C&F charges and wastage, did not clearly correlate with the declared assessable value. In addition, the cost construction showed a buffer element and the valuation position for job-work goods was uncertain during the relevant period, so the demand failed on suppression.

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Issues: Whether the extended period of limitation under the proviso to section 11A could be invoked for the duty demand on job-work clearances on the basis of alleged suppression of facts.

Analysis: The demand related to valuation of dipped fabrics manufactured on job-work basis during an earlier period. The annexures to the show cause notices were party-wise and period-wise, not job-order-wise, and did not enable a precise finding of suppression in relation to each consignment. The material relied on for bank charges, letter of credit charges, to-bond and de-bond charges, C&F charges, and wastage did not establish a clear co-relation with the assessable value declared by the appellant. The cost construction also showed a buffer element, and the legal position on valuation of job-work goods was not free from uncertainty during the relevant period.

Conclusion: The extended period of limitation was not invocable, and the duty demand could not be sustained on the basis of suppression of facts.

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