Extended limitation requires specific suppression details; bare allegations and unrebutted correspondence kept the demand within the normal period.

Extended limitation could not be invoked where the show cause notice alleged suppression only in general terms and did not specify how information was concealed from the Department. The Tribunal noted that the Commissioner (Appeals) had already restricted the demand to the normal six-month period on the basis of long-standing correspondence between the parties, and the Revenue produced no rebuttal evidence to displace that finding. On that factual basis, the demand remained confined to the normal period and the Revenue's appeal was rejected.

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Issues: Whether the extended period of limitation could be invoked on the allegation of suppression of facts.

Analysis: The appeal concerned the same order-in-appeal that had already been considered in earlier connected matters. The Tribunal noted that the Commissioner (Appeals) had restricted the demand to the normal period of six months on the basis of correspondence exchanged between the respondents and the Department over several years, and that no rebuttal evidence had been produced by the Revenue. It was further noted that the show cause notice contained only a bare allegation of suppression without particulars showing how information had been concealed from the Department.

Conclusion: The extended period of limitation was not invocable. The demand was confined to the normal period, and the Revenue's appeal was rejected.

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