Polished ceramic tiles are not glazed tiles; extended excise limitation cannot apply without proved suppression.

Polished ceramic tiles without a coating of melted glass are not treated as glazed tiles for tariff purposes because glazing requires an actual glaze layer, while mere mechanical polishing or a shiny finish is insufficient. The text also states that the extended excise limitation period applies only on proof of suppression, fraud, collusion, wilful misstatement or similar deliberate conduct; absent such suppression, the longer period cannot be invoked. On these stated findings, both classification and limitation were resolved in favour of the assessee, and the Tribunal's order was upheld.

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Issues: (i) Whether polished ceramic tiles, without a coating of melted glass, are classifiable as glazed tiles under the tariff; and (ii) Whether the demand of excise duty was barred by limitation for want of suppression.

Issue (i): Whether polished ceramic tiles, without a coating of melted glass, are classifiable as glazed tiles under the tariff.

Analysis: Glazed tiles are understood in common parlance as tiles having a coating of melted glass. Mere polishing or a shiny appearance does not amount to glazing. The manufacturing process showed only mechanical polishing and no application of glaze material on the tile surface. Glazing and polishing are distinct processes, and vitrification is also separate from glazing.

Conclusion: The tiles were not glazed tiles and were not classifiable under the glazed-tile heading; this issue was decided in favour of the assessee.

Issue (ii): Whether the demand of excise duty was barred by limitation for want of suppression.

Analysis: The extended limitation period applies only where suppression, fraud, collusion, wilful misstatement, or similar deliberate conduct is established. On the facts found, there was no suppression, and that factual finding was not open to interference.

Conclusion: The extended period of limitation did not apply; this issue was also decided in favour of the assessee.

Final Conclusion: The appeal failed on both classification and limitation, and the Tribunal's order in favour of the assessee was upheld.

Ratio Decidendi: Polishing alone does not constitute glazing for tariff classification, and the extended limitation period cannot be invoked absent proved suppression or other deliberate concealment.

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