Actual service of section 143(2) notice within limitation is mandatory; dispatch alone does not satisfy the statute.

Actual service of a notice under section 143(2) within the prescribed limitation period is required; mere issuance or dispatch by registered post on the last day does not satisfy the statutory condition if service is not effected within time. On the facts stated, same-day service was not possible in the absence of hand delivery, so the notice was held to be time-barred. No substantial question of law arose on the record, and the revenue's appeal could not succeed.

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Issues: Whether notice under section 143(2) of the Income-tax Act, 1961 was served on the assessee within the prescribed period of limitation.

Analysis: The notice was issued by registered post on the last day of limitation. Service on the same day was not possible in the absence of hand delivery. The statutory requirement is actual service of the notice within limitation, not merely its dispatch or issuance.

Conclusion: The notice was not served within limitation. No substantial question of law arose, and the revenue's appeal could not succeed.

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