Validity of Notice via post for delivery, posted on last day of Limitation Period & Notice by affixture

Brief of the Case ITAT Lucknow held In the case of ITO vs. Shri Rajesh Agarwal that undisputedly notice of hearing under section 143(2) was issued on the last day of limitation/prescribed period for issuance of notice i.e. on 30.9.2011 at 15.19 hours by speed post. Therefore, the CIT (A) has rightly held that probability of service of the said notice by midnight on the same day is very remote. Further as service of notice by affixture is concerned, under Code of Civil Procedure, the mode of service by way of substituted service can only be invoked when service upon the assessee is not possible...