Das, J.

1. These are two applications for a certificate for leave to appeal to the Supreme Court under Article 133 of the Constitution. The facts are these : The petitioners were assessed to tax under Sec.23, Income Tax Act to heavy amounts well over Rs. 20,000/-; as a matter of fact, the petitioners were assessed to tax exceeding several lakhs.

Against these assessment orders the petitioners filed two applications for the issue of writs under Articles 226 and 227 of the Constitution, on the main grounds that the orders of assessment were without jurisdiction and vitiated by errors apparent on the face of the record. These two writ applications were dismissed summarily by a Bench of this Court by an order dated 23-3-1955. The petitioners now ask for a certificate for leave to appeal to the Supreme Court from the said order of the Bench, dated 23-3-1955.

2. The contention of learned Counsel for the petitioners is that his clients have a right to a certificate under Sub-clause (a) or Sub-clause (b) of Clause (1) of Article 133 of the Constitution.

In the two applications for a certificate, Article 132 of the Constitution has also been mentioned, but learned Counsel for the pe