1. This reference, under the Income-tax Act, arises out of two assessments made on Malayalam Plantations Limited, Quilon, for the Malabar years 1122 and 1124 under the Travancore Income-tax Act. Against those assessments the assessee, the Malayalam Plantations Limited, preferred two appeals to the Appellate Assistant Commissioner of Income-tax, Trivandrum, Income-tax Appeal No. 443 of 1124 against the assessment for 1122 and Income-tax Appeal No. 975 of 1124 against the assessment for 1124. Both these appeals were disposed of by the Appellate Assistant Commissioner on 30-8-1952. Against the orders passed by him on that date the assessee preferred two appeals to the Income-tax Appellate Tribunal, Madras Bench-B I.T. Appeals 5007 and 5008 of 1952-53. These appeals were filed on 21-11-1952. The Appellate Tribunal, dismissed both of them on the ground that they were time-barred, that is, that they were filed after sixty days from the date of the communication of the Appellate Assistant Commissioner's order to the assessee. The position which the assessee took up before the Appellate Tribunal was that the appeals were not time barred. But by way of abundant caution the asses