Extended excise limitation fails without specific allegations of suppression, misrepresentation, or intent to evade duty.

Excise demands cannot be brought within the extended limitation period unless the show-cause notice specifically alleges misrepresentation, wilful suppression of facts, or intent to evade duty. Where the notices rely on Rule 10A and Section 11A but omit these statutory ingredients, only the normal six-month period applies. On that basis, demands raised beyond the normal period are time-barred. The text also notes that a remand required reconsideration of both clearance value and limitation, but the decisive point remained the absence of allegations necessary to sustain extended limitation.

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Issues: Whether the excise demands were barred by limitation in the absence of any allegation of misrepresentation, wilful suppression of facts, or intent to evade duty in the show-cause notices.

Analysis: The remand order was read as requiring reconsideration of both the clearance value and the plea of limitation. The show-cause notices invoked recoverability under Rule 10A and Section 11A, but they did not allege misrepresentation, wilful suppression, violation of the Act or Rules, or intent to evade duty. In the absence of these necessary ingredients, the extended period could not be applied, and only the normal six-month period was available. The demands, having been raised beyond that period, were therefore time-barred.

Conclusion: The limitation plea was accepted and the demands were held to be barred by time.

Ratio Decidendi: The extended period of limitation in excise matters cannot be invoked unless the notice specifically alleges the statutory ingredients of misrepresentation, wilful suppression, or intent to evade duty.

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