Limitation for stock-verification duty demands applies under Section 11A; absent suppression, the extended period cannot be used.

Demands arising from shortages found in annual stock verification are subject to the limitation period under Section 11A. Where the show cause notice is issued beyond the normal six-month period and does not allege suppression of facts, misstatement, collusion, or fraud, the extended limitation period cannot be invoked. On that basis, the Tribunal treated the recovery as time-barred and upheld the Commissioner's order.

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Issues: Whether the demand of duty arising from shortages detected in annual stock verification under Rule 233A was governed by the limitation prescribed under Section 11A, and whether the show cause notice issued after six months was barred by time in the absence of suppression, misstatement, collusion, or fraud.

Analysis: The Tribunal held that demands based on deficiencies noticed in stock verification reports are not outside the limitation framework and that the time limit under Section 11A applies to such recoveries. It also noted that, where the notice is issued beyond the normal limitation period and the notice itself contains no allegation of suppression of facts, misstatement, collusion, or fraud, the extended period cannot be invoked.

Conclusion: The demand was time-barred, and the Revenue's challenge to the Commissioner's order failed.

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