Approved classification lists and assessed returns barred extended limitation; later reclassification was only a change of opinion.

Approved classification lists and assessed RT-12 returns prevented invocation of the extended limitation period, because the later reclassification was treated as a mere change of opinion rather than suppression of material facts. On those facts, duty demand and penalty could not be sustained retrospectively, and the reclassification could operate only prospectively. The appeal therefore succeeded on limitation, and the merits were not examined.

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Issues: Whether the demand of duty and penalty were barred by limitation in view of approved classification lists and assessed RT-12 returns.

Analysis: The classification lists specifically referred to the goods and were approved by the proper officer, and the RT-12 returns for the relevant period were also assessed. On those facts, the dispute was one of change of opinion regarding classification rather than suppression of material facts. A classification change, in such circumstances, could operate only prospectively.

Conclusion: The demand was barred by limitation and the appeal succeeded on that ground; the merits were not examined.

Ratio Decidendi: Where the relevant classification lists have been approved and the returns assessed, a later reclassification amounts to a mere change of opinion and cannot sustain invocation of the extended period or retrospective demand.

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