JUDGMENT

 This is an appeal by certificate. The Allahabad High Court decided that the date of the communication of the order will be the starting point of limitation for filing an appeal under Section 15 of the U. P. Motor Vehicles Taxation Act. The respondent wanted exemption of tax in respect of his motor vehicle for a certain period. He applied to the Taxation Officer, Kanpur. The order rejecting his prayer was communicated in the letter of Taxation Officer dated October 20/24, 1964 through the Regional Transport Authority, Kanpur. The respondent received that letter on Oct. 29, 1964. His appeal was within 30 days of Oct. 29, 1964 but beyond 30 days of Oct. 24, 1964. If Oct. 24, 1964 could be taken to be the date of the order then obviously the appeal was out of time. If, however, the date of the order in Section 15 of the Uttar Pradesh Motor Vehicles Taxation Act, in the context, meant the date of the communication of the order, then the appeal was within time. Following the decision of this Court in Raja Harish Chandra Raj Singh v. The Dy. Land Acquisition Officer, (1962) 1 SCR 676, the High Court has held in favour of the respondent, hence this appeal.

2. In our opinion, the j