Extended limitation under section 11A fails where classification was approved and departmental knowledge negates suppression.

Approved classification lists and departmental knowledge can defeat reliance on the extended limitation period under section 11A. The goods were described as steel ingots including steel melting scrap, and the classification list was approved by the Assistant Collector. The record showed that production of runners and risers was within the department's knowledge from the outset, and officers were expected to make proper inquiry before granting approval under rule 173B. On those facts, there was no deliberate suppression or misstatement with intent to evade duty, so the extended period could not be invoked and the demand beyond six months was time-barred.

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Issues: Whether the demand could be sustained by invoking the extended period under section 11A on the ground of suppression or misstatement, and whether the approved classification list and departmental knowledge negatived such invocation.

Analysis: The classification list had been filed describing the goods as steel ingots including steel melting scrap and had been approved by the Assistant Collector. The record showed that the production of runners and risers was within the department's knowledge from the beginning, and the officers were expected to make proper inquiry before granting approval under rule 173B. On the facts, there was no deliberate suppression or misstatement with intent to evade duty, and the department could not rely on the extended limitation period. As the show cause notice covered a period beyond six months, the demand was consequently time-barred.

Conclusion: The invocation of the extended period was not justified and the demand was barred by limitation.

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