https://www.taxtmi.com/article/detailed?id=17243 Extended limitation for duty recovery requires more than an incorrect valuation or short payment. The Revenue must independently establish wilful misstatement or suppression of material facts with intent to evade duty. Where material valuation facts were already known to the Department, an assessee's omission cannot, without more, be treated as suppression to overcome expiry of normal limitation. A show-cause notice must identify the factual basis for concealment, wilfulness, and intent; statutory labels alone are insufficient. This distinction remains relevant to GST proceedings involving fraud, wilful misstatement, or suppression. en-us Fri, 21 Aug 2026 08:28:57 +0530 Fri, 21 Aug 2026 08:28:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=17243 Extended limitation for duty recovery requires more than an incorrect valuation or short payment. The Revenue must independently establish wilful misstatement or suppression of material facts with intent to evade duty. Where material valuation facts were already known to the Department, an assessee's omission cannot, without more, be treated as suppression to overcome expiry of normal limitation. A show-cause notice must identify the factual basis for concealment, wilfulness, and intent; statutory labels alone are insufficient. This distinction remains relevant to GST proceedings involving fraud, wilful misstatement, or suppression. Articles Central Excise Fri, 21 Aug 2026 08:28:57 +0530 https://www.taxtmi.com/article/detailed?id=17243