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    <description>Demand of duty and penalty were held time-barred because the department could not establish suppression of facts to justify the extended limitation period. The assessee had filed classification declarations, cleared goods under invoices describing the product, and the unit had been visited by departmental officers and audited, all of which supported departmental knowledge of the manufacturing activity. In these circumstances, the extended period was not available, and the demand and consequential penalty could not be sustained on limitation grounds.</description>
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      <description>Demand of duty and penalty were held time-barred because the department could not establish suppression of facts to justify the extended limitation period. The assessee had filed classification declarations, cleared goods under invoices describing the product, and the unit had been visited by departmental officers and audited, all of which supported departmental knowledge of the manufacturing activity. In these circumstances, the extended period was not available, and the demand and consequential penalty could not be sustained on limitation grounds.</description>
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