Extended limitation cannot revive a duty demand when all material facts were already disclosed to the department.

Duty demand was held time-barred because the appellants had already disclosed the sales pattern, invoices, price lists, statements and a Chartered Accountant's certificate, putting the department in possession of all material facts. On that basis, suppression and related-person allegations were not established, and the extended limitation period could not be invoked. A later addendum notice issued after the matter had been closed for orders could not lawfully introduce new grounds or a fresh case under the extended period. The impugned order was set aside and consequential relief followed.

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Issues: Whether the demand of duty was barred by limitation, and whether the extended period could be invoked on the basis of a later addendum notice alleging suppression and related-person transactions.

Analysis: The appellants had disclosed the sales pattern, invoices, price lists, statements and a Chartered Accountant's certificate at the earlier stage itself. The department was already aware of the material facts, and no further investigation had established suppression or financial flow-back. An addendum notice issued after the matter had been closed for orders attempted to introduce new grounds and a fresh case under the extended period. On these facts, the invocation of the larger period was not sustainable, and even the original notice was held to be time-barred.

Conclusion: The demand was barred by time and the extended limitation could not be invoked against the appellants.

Final Conclusion: The impugned order was set aside and the appeal succeeded with consequential relief.

Ratio Decidendi: Where the department is already in possession of all material facts and seeks, by a later addendum notice, to introduce new allegations and invoke the extended period, the demand is time-barred and the extended limitation cannot be applied.

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