Full and correct disclosure failed where declarations did not clearly identify exempt goods and wilful misstatement was sustained.

Full and correct disclosure was required to deny the department the extended period, but the declarations were held insufficient because they did not clearly align the manufactured goods with the claimed exemption entries and used only a general description of the process. The invoices and declarations were found not to disclose the crucial distinction between acrylic sheets and cellulose acetate, and the chemical examiner's report supported that acrylic sheets could not be manufactured from cellulose acetate. Trade nomenclature was treated as irrelevant where classification depended on chemical identity, so the disclosure was not accepted as complete and the allegation of wilful misstatement was sustained; the extended period was therefore rightly invoked and the appeal failed.

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Issues: Whether the assessee had made a full and correct disclosure in the declarations so as to deny the department the benefit of the extended period, and whether the allegation of wilful misstatement was sustainable.

Analysis: The declarations did not specifically align the goods manufactured with the exemption entries claimed, and the description of the manufacturing process was found to be too general to show that the department had been clearly apprised of the true nature of the exempted goods. The invoices and declarations suggested that acrylic sheets were being described in a manner that did not disclose the crucial distinction from cellulose acetate. The chemical examiner's report supported the view that acrylic sheets could not be manufactured from cellulose acetate, and trade nomenclature was held to be irrelevant where classification depended on chemical identity. On this material, the disclosure was not treated as full and correct, and the department's allegation of wilful misstatement was accepted.

Conclusion: The extended period was rightly invoked and the appeal failed.

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