Limitation for Modvat credit reversal ran from the RT 12 return date, making the demand time-barred.

Limitation for demanding reversal of Modvat credit taken before filing the declaration was computed from the date the RT 12 return was filed, or should have been filed, because that return and its supporting records were statutory assessment documents. On the facts, the show cause notice was issued beyond six months from the RT 12 return date, so the demand was barred by limitation.

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Issues: Whether the demand for reversal of Modvat credit taken before filing the declaration was barred by limitation.

Analysis: The relevant date for computing limitation was held to commence from the date on which the RT 12 return was filed or should have been filed, since the return and accompanying records were statutory documents for assessment purposes. On the facts, the show cause notice was issued beyond six months from the filing of the RT 12 return.

Conclusion: The demand was barred by limitation and the appeal failed.

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