Limitation for customs demand notice turns on actual service within time, not mere posting of the envelope.

A show cause notice under Section 28 had to be served within the prescribed period from the relevant date, and service within time was essential to sustain the demand. Even on the assumption that the sanction of refund of the security deposit was the relevant date, the notice had to be served on or before 3-2-2000. Mere tender of the envelope to the post office on 4-2-2000 did not amount to service within limitation, so the notice was time-barred and the demand could not be sustained.

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Issues: Whether the show cause notice issued under Section 28 was barred by limitation.

Analysis: The demand notice had to be served within the prescribed period from the relevant date. Even assuming the date of sanction of refund of the security deposit as the relevant date, the notice was required to be served on or before 3-2-2000. Mere tender of the envelope to the post office on 4-2-2000 did not amount to service within time.

Conclusion: The notice was barred by limitation and the demand could not be sustained.

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