Provisional assessment limitation runs from finalisation, so a later excise demand was not time-barred.

Provisional assessments under Rule 9B delayed the start of limitation until finalisation of the assessments, so a demand notice issued after finalisation was not time-barred. The limitation objection failed because the relevant period ran from the date the assessments were finally determined, not from the original clearances. A separate objection on the duty break-up was treated as a clarification issue only and did not affect liability. The demand was therefore upheld.

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Issues: Whether the demand was barred by limitation when it arose from provisional assessments later finalised.

Analysis: The show cause notice and record indicated that the clearances had been provisionally assessed under Rule 9B of the Central Excise Rules and were later finalised before the demand notice was issued. In that situation, the relevant period for limitation runs from finalisation of the assessment, not from the original clearances. The plea that the demand was time-barred was therefore not sustainable. The separate grievance regarding the exact break-up of the confirmed duty was treated only as a matter for clarification and worksheet supply, not as a substantive ground affecting liability.

Conclusion: The limitation objection was rejected and the confirmed demand was upheld.

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