Extended limitation for misclassification requires suppression or misstatement, not mere classification dispute.

Extended limitation cannot be invoked merely on an allegation of misclassification where the goods were consistently classified under the same heading in approved classification lists and the record shows no substantive material of suppression or misstatement. Misclassification by itself was treated as insufficient to trigger the longer period. The extended period of limitation was therefore held unjustified, and the Revenue's challenge failed.

---

---

Issues: Whether the extended period of limitation could be invoked on the basis of alleged misclassification of goods, in the absence of material showing suppression or misstatement by the assessee.

Analysis: The goods had been classified under the same heading in the approved classification lists for successive years, and the show cause notice proceeded on alleged misclassification. The record did not contain any substantive material to establish suppression or misstatement, and misclassification by itself was treated as insufficient to justify the longer limitation period.

Conclusion: The invocation of the extended period of limitation was held to be unjustified, and the Revenue's challenge failed.

---