Extended limitation in duty cases requires specific allegations; vague notices cannot sustain demand or penalty.

A show cause notice issued beyond the normal limitation period can sustain duty demand and penalty only if it expressly alleges the specific grounds for invoking the extended period, such as fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty. A notice that merely relies on the larger period without particularising those ingredients does not inform the person proceeded against of the exact case to meet and fails the requirement of natural justice. In the absence of such particulars, invocation of the extended period is not sustainable, and the demand and penalty cannot be upheld.

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Issues: Whether the show cause notice issued after six months could sustain penalty and duty demand by invoking the extended limitation period without stating particulars of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty.

Analysis: The notice was issued beyond the normal period and could survive only on the basis of the ingredients that justify the extended period. The notice did not allege, much less particularise, any such ground. A person proceeded against must be informed of the exact allegation so as to meet the case against it, and the ground for invoking the larger period cannot be assumed to be implicit in the notice. Absence of such particulars offended the requirement of natural justice.

Conclusion: The invocation of the extended period was not sustainable and the demand and penalty could not be upheld.

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