Provisional assessment requires strict Rule 9B compliance; without it, the duty demand was held within limitation.

Assessments could not be treated as provisional where the required bond and procedural steps for provisional assessment under Rule 9B were not followed, so the limitation plea based on provisional assessment failed. The authorities distinguished cases involving admitted provisional assessment and accepted that the assessee did not dispute the classification change or the consequential duty computation. The duty demands were therefore not time-barred, and confirmation of duty under Section 11A was upheld.

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Issues: Whether the duty demands were barred by limitation on the footing that the assessments were provisional, and whether the demands confirmed under Section 11A were sustainable.

Analysis: The classification list approvals were not accompanied by the bond and procedural requirements necessary for provisional assessment under Rule 9B. Since the prescribed provisional assessment procedure was not followed, the assessments could not be treated as provisional. The decisions relied upon by the appellant were distinguished because they applied to cases of admitted provisional assessment. On merits, the appellant did not dispute the classification change and the consequential duty working.

Conclusion: The duty demands were not time-barred and the confirmation of duty under Section 11A was upheld against the assessee.

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