N.V.Balasubramanian, J.: C.M.A.No.896 of 2004 is preferred against the order passed by the 3rd respondent in No.6061/N3/2004 dated February, 2004. C.M.A.No.897 of 2004 is preferred against the order passed by the 3rd respondent in No.5867/N3/2004 dated February, 2004.

2. In both the orders, the 3rd respondent has rejected the appeals preferred by the appellants on the ground that the orders of the Revenue Divisional Officer, Sivakasi are dated 18.11.2003, but the appeals were preferred beyond the period of two months as provided under Sec.47-A of the Indian Stamps Act, 1899.

3. We heard Mr.A.Sivaji, learned counsel appearing for the appellants and learned Government Advocate for the respondents and with the consent, the appeals are taken up for hearing.

4. Mr.A.Sivaji, learned counsel appearing for the appellants submitted that the orders of the 3rd respondent are not sustainable as the said officer has taken into account the date of the order for the purpose of deciding the question whether the appeals were filed in time or not but omitted to take note of the date of service of the orders and if that is taken into account, the appeals preferred are within time. Learned counsel appe

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