Extended limitation and suppression of facts fail where job-work disclosures were already made to the department.

Prior disclosures of the job-work activity, removal of inputs and the nature of the process defeated any allegation of suppression of facts, so the extended period of limitation could not be invoked. Because the department already had the relevant information, the show-cause notice issued long after the transactions was beyond the prescribed period and the demand was unsustainable on limitation.

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Issues: Whether the demand was barred by limitation in view of the prior disclosures made to the department and the issuance of the show-cause notice beyond the prescribed period.

Analysis: The correspondence exchanged between the principal unit, the assessee and the departmental officers showed that the job-work activity, removal of inputs and the nature of the process were all disclosed. In such circumstances, the department had no basis to invoke the extended period of limitation, as there was no suppression of facts. The show-cause notice, issued long after the relevant transactions, was therefore beyond time.

Conclusion: The demand was held to be unsustainable on limitation and the appeal was allowed.

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