Limitation barred duty demand and penalty where suppression could not be based on Government notifications.

Duty demands and penalty were held barred by limitation because the show cause notice was issued beyond the normal period and the extended period could not be invoked. The allegation of suppression failed, as the nondisclosure related to Government notifications, and such notifications could not be treated as facts suppressed by the assessee for the purpose of extension of time. The impugned order was set aside on limitation grounds, and the appeal succeeded.

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Issues: Whether the duty demands and penalty were barred by limitation on the ground that the show cause notice was issued beyond the normal period and the extended period was unavailable.

Analysis: The demand was raised long after the relevant period. The objection of suppression could not be sustained because the alleged non-disclosure related to Government notifications, and such notifications cannot be treated as facts suppressed by the assessee for invoking the extended period.

Conclusion: The demands were barred by limitation and the impugned order was set aside on that ground. The appeal succeeded.

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