Show cause notice limitation under Section 11A requires quantified demand; prior departmental letters cannot extend the time bar.

For limitation under Section 11A, only a statutorily compliant show cause notice specifying the demand can be relied upon; earlier departmental letters that merely called for record maintenance or payment, without quantifying liability, could not be treated as part of the notice or as its substitute. In the absence of a valid notice covering the disputed period, the demand beyond six months was time barred, and the appellate finding that the demand was unsustainable was upheld.

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Issues: Whether departmental letters issued prior to the show cause notice could be treated as part of the show cause notice for computing limitation under Section 11A, and whether the demand for the relevant period was barred by limitation.

Analysis: Section 11A contemplates issuance of a proper show cause notice specifying the demand. Earlier communications that merely advised maintenance of records or payment of dues, without quantifying the demand, could not be equated with a statutory show cause notice or treated as part of it. In the absence of a valid notice covering the period in dispute, the demand beyond six months remained time barred.

Conclusion: The departmental letters were not valid show cause notices and could not extend or satisfy the limitation requirement. The finding that the demand was barred by limitation was upheld.

Final Conclusion: The demand held time barred by the appellate authority remained unsustainable, and the revenue appeal failed.

Ratio Decidendi: For limitation under Section 11A, only a statutorily compliant show cause notice specifying the demand can be relied upon; prior non-quantified departmental communications cannot be treated as a substitute or as part of such notice.

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