Extended limitation cannot be invoked where full disclosure preceded de-bonding and no suppression of facts was shown.

In a de-bonding dispute involving an EOU, the extended period of limitation was held unavailable because the unit had fully declared its stock and duty position, and the jurisdictional Central Excise authorities had verified the particulars before issuing the no dues certificate and final de-bonding order. With no suppression of facts or deliberate misstatement established, the duty demand failed on limitation. As the demand was time-barred, the merits of the duty computation were not examined.

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Issues: Whether the extended period of limitation could be invoked to sustain the duty demand arising from de-bonding of the EOU.

Analysis: The unit had made a full declaration of the stock and duty position at the time of de-bonding, and the jurisdictional Central Excise authorities had verified the details before issuing the no dues certificate, followed by the final de-bonding order. In these circumstances, the ingredients necessary for invoking the extended limitation period, including suppression of facts or deliberate misstatement, were not established. Since the demand itself failed on limitation, the merits of the duty computation were not examined.

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

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