Extended limitation period not invocable where import records fully disclosed facts and officers repeatedly examined exemption claims.

Import declarations disclosed the nature of the goods, the Bills of Entry contained the relevant particulars, and departmental officers had repeatedly examined the exemption claim, raised queries, inspected the goods, and considered the technical write-up. On those facts, no material suppression of facts could be attributed to the importer, so the extended period of limitation was not available and the show cause notice was time-barred. The demand therefore failed on limitation.

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Issues: Whether the demand was barred by limitation and whether the extended period could be invoked on the facts of the case.

Analysis: The import declarations disclosed the nature of the goods, the Bills of Entry carried the relevant particulars, and the departmental officers had repeatedly examined the entitlement to exemption, raised queries, inspected the goods, and considered the technical write-up. In these circumstances, no material suppression of facts could be attributed to the importer, and the record did not justify a departure from the finding that the show cause notice was time-barred.

Conclusion: The extended period of limitation was not invocable and the demand failed on limitation.

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