JUDGMENT Govindan Nair, J 1. The Kerala Agricultural Income Tax Appellate Tribunal, Trivandrum has referred the following questions to this court under section 60(1) of the Agricultural Income Tax Act, 1950 (shortly stated the Act):” (i) Whether on the facts and circumstances of the case the Tribunal is correct in holding that the agreement entered into between the appellant and M/s George Varghese & Co., on 23rd March 1964 is not a lease deed ? (ii) Whether on the facts and circumstances of' the case the Tribunal is correct in holding that the disputed amount of Rs. 1,76,000 does not represent rent within the meaning of section 2 (a) (i) of the Agricultural Income Tax Act, 1950? 2. The year of account is that which ended on 31st March 1965 and the assessment year 1965-66. The assessee is the Woodlands Estates Ltd., which owns a rubber estate having an extent "of 384 acres. The Woodlands Estates Ltd., entered into an agreement on 23rd March 1964 with M/s George Varghese & Co. This agreement is enclosure D to the Statement of the Case. We may extract below statements in the preamble to this agreement: "And whereas the Rubber trees standing in the balance of 303 acres more particularly described in the schedule hereunder written in Braemore Estate have become old and uneconomical having been intensively tapped for the last two years. And whereas with a view to replant rubber in the said 303 acres the vendor has agreed to sell and the purchaser has agreed to purchase all the said rubber trees with their roots standing on the vendor's said properties with rights to do with the trees whatever the purchaser considers fit including slaughter tapping till they are felled and removed for the consideration and on the terms and conditions hereinafter mentioned." 3. Then it was mentioned in the agreement that the consideration for the sale of the rubber trees was Rs. 4,31,775. This amount shall be paid in monthly instalment of Rs. 16,000 on or before the 25th day of each month for the year commencing from 1st April, 1964; a monthly instalment of Rs. 15,000 on or before the 25th day of each month for the year commencing from 1st April, 1965; and a monthly instalment of Rs. 4,31,775. This amount shall be paid in monthly instalment of Rs. 16,000 on or before the 25th day of each month for the year commencing from 1st April, 1964; a monthly instalment of Rs. 15,000 on or before the 25th day of each month for the year commencing from 1st April, 1965; and a monthly instalment of Rs. 10,000 on or before the 25th day of each month for the first five months for the year commencing from 1st April 1966 and the last instalment of Rs. 9,775 on or before the 25th day of September, 1966. We may refer to paragraphs 3, 7 and 9 of the agreement; which are in the following terms:” "The schedule properties on which the rubber trees hereby agreed to be sold are standing shall continue in the possession of the vendor and since the said properties are intended to be replanted the vendor shall have the full and unrestricted right to make pits, fence, to cut roads and paths, to put up buildings, to undertake and do all such preparatory work for the proposed replanting of rubber but the purchaser and his employees shall have the right to enter on the said properties and do all that is necessary for slaughter tapping cutting and removing the trees hereby agreed to be sold to him and to do such other things that may be deemed necessary and expedient by the purchaser for the profitable implementation of the terms of this agreement without hindrance to the vendor's work connected with replanting. Provided also that in order to facilitate such preparatory work of the vendor and the replanting the purchaser shall to the satisfaction of the vendor do the needful to keep under control the growth of Eupothorium and other weeds on the said lands. All taxes, duty other levies which may become payable to any , governmental or local, or other authorities in respect of the said trees or latex or rubber at any stage of purchaser's subsequent disposal of the same by the purchaser shall be borne by the purchaser and the purchaser shall keep the vendor, indemnified against all such claims. Land tax and plantation tax, if any, relating to the schedule properties shall be paid by the vendor. Land tax and plantation tax, if any, relating to the schedule properties shall be paid by the vendor. The dates stipulated herein for the payment of each instalment and for slaughter tapping, cutting and removing the trees and for removing all sheds put up by the purchaser and clearing the site shall be of the essence of this contract. Upon the due and faithful performance and completion of this Agreement by the purchaser the earnest deposit of Rs. (5000) five thousand only already paid to vendor shall be refunded to the purchaser but with interest." 4. During the year of account, an amount of Rs. 1,76,000 was received by the assessee from M/s George Varghese and Co. The question before the Taxing Authority was whether this amount represented agricultural income of the assessee liable to be taxed under the Act. The Assistant Commissioner of Agricultural Income-tax and Sales tax (Special), Kottayam held that the entire amount of Rs. 1,76,000 represented agricultural income and taxed this amount, and on appeal before the Deputy Commissioner, this decision was confirmed, but on further appeal before the Tribunal, it was found that the agreement in question did not represent any lease and that the amount received was not rent. It also found that the income, if, any, received by slaughter tapping of the rubber trees, was income of M/s George Varghese and Co., and that the assessee cannot be said to be a recipient of that income and, therefore, held that the sum of Rs. 1,76,000 was not liable to be taxed under the Act. 5. It was contended that the Taxing Authority had proceeded on the basis that the agreement dated 23rd March 1964 provided that the trees should be subjected to slaughter tapping and that whatever was received from slaughter tapping should be taken by M/s George Varghese and Co., and that such receipt represented income. There is no specific finding as to whether such receipts, if any, has also been reflected in the consideration that is provided in the agreement, payable to the assessee; but we get the impression that the Authority has proceeded on the basis that the consideration must, to the extent it contains receipts from slaughter tapping must represent income. There is no specific finding as to whether such receipts, if any, has also been reflected in the consideration that is provided in the agreement, payable to the assessee; but we get the impression that the Authority has proceeded on the basis that the consideration must, to the extent it contains receipts from slaughter tapping must represent income. We wish to mention at this stage that the point was not raised in the appeal before the Tribunal, that in any view of the matter the Inspecting Assistant Commissioner and the Deputy Commissioner of Agricultural Income-tax erred in concluding that the entire sum of Rs. 1,76,000 represented the agricultural income. This aspect has not been dealt with by the Tribunal in its order nor has it been adverted to. We do not even know whether this point was urged before the Tribunal. Perhaps it was unnecessary to go into it in the light of the conclusion reached that no part of Rs. 1,76,000 could be assessed for agricultural income-tax. We may now quote the relevant part of the Tribunal's order: "The last and serious contention in this appeal is against the estimate of Rs. 1,76,000 as lease amount from slaughter tapping of rubber trees. By an agreement dated 23rd March 1964, between the appellant/company and the firm, viz., M/s George Varghese and Co., Kottayam the old rubber trees in 303 acres of the company's Braemore estate were sold to the said firm for cutting and removing as the trees have become old and uneconomical and as the area had to be prepared for replanting. The price stipulated in the agreement is Rs. 4,31,775. Out of this total consideration Rs. 1,76,000 was received in the previous year relevant for the assessment under review. The stipulation in the agreement is that the payment should be made each month from the 1st day of April, 1964, that the trees in 100 acres of one contiguous block out of 303 acres to be cut and removed in any case on or before 15th March, 1966, those from another 103 acres before 15th March 1967 and those remaining before 15th June, 1967. The appellant's case before the authorities below and also before us is that the consideration received by the assessee is towards price of rubber trees sold out right to the purchasing firm. The appellant's case before the authorities below and also before us is that the consideration received by the assessee is towards price of rubber trees sold out right to the purchasing firm. The department's stand is that part of the amount of consideration (80 per cent) represents receipts under slaughter tapping and only the balance of 20 per cent represent the value of trees and that this can be inferred from the several clauses of the agreement and therefore that the agreement is not ostensible one for sale of trees. The presumption of the department is gathered from certain clauses in the agreement. The preamble says that the assessee has agreed to sell and the purchaser had agreed to purchase all the said trees with their roots standing on the vendor's properties with rights to do with the trees whatever the purchaser considers fit including slaughter tapping till they are felled and removed, for the consideration, and on the terms and conditions of the agreement, Clause 3 of the agreement stipulates that the purchaser and his employees shall have the right to enter on the said properties and do all that is necessary for slaughter tapping, cutting and removing the trees hereby agreed to be sold to him and to do such other things that may be deemed necessary and expedient by the purchaser. No doubt, the possibility and operation of slaughter tapping was in the contemplation of both the appellant and the purchaser. The question to be considered is whether the appellant company derives any agricultural income from slaughter tapping. The appellant's learned advocate strenuously argued that what the appellant had transferred is only standing rubber trees to be cut and removed by the purchaser within a stipulated period with freedom for the purchaser to do whatever he deems fit with the trees including slaughter tapping and that even if the purchaser had derived income by slaughter tapping it is not the appellant's income and the appellant is not concerned with what the purchaser does with the trees. We find there, is substance in this contention. In order to make the appellant liable for assessment on income from slaughter tapping the appellant should derive income by its own agricultural operations or received is by way of rent for lease of the land and trees for such operation. We find there, is substance in this contention. In order to make the appellant liable for assessment on income from slaughter tapping the appellant should derive income by its own agricultural operations or received is by way of rent for lease of the land and trees for such operation. Evidently the appellant had not done any agricultural operations for deriving income by slaughter tapping. As contended by the appellant's counsel the agreement can by no stretch of imagination be described as a lease for slaughter tapping; nor is there any rent amount specified for slaughter tapping. So it cannot be said that the appellant had derived any income by way of rent also by leasing of the land for slaughter tapping. It was because the trees have become uneconomical and the estate had to be prepared for replanting that the trees have been sold for cutting and removal. Of course, in fixing the value for the trees the potentiality for yielding some latex within the stipulated period for removal of trees might also have been taken into consideration by the seller and purchaser. But merely by that fact it is not possible to say that the appellant derived income from slaughter tapping. Whatever income derived by slaughter tapping is the income derived by the purchaser from the trees for which they have paid a price, probably a higher price considering the yield of latex that will be obtained by them also. In this view we find that there is no justification for additional tapping. This amount will be deleted. The assessment will be modified accordingly. Excess tax paid if any shall be refunded. The appeal is partly allowed as stated above." 6. The Commissioner of Agricultural Income-tax moved an application for reference under section 60 (1) of the Act seeking to raise the question that have been referred to us. This was objected to by the assessee on the ground that the questions did not arise from the order of the Tribunal. Rejecting the objection this reference has been made. 7. The agreement dated 23rd March 1964 came up for consideration before this Court at the instance of the Commissioner for Agricultural Income-tax in Commissioner of Agricultural Income-tax, Kerala v. M/s George Varghese and Co., Kottayam I.L.R. 1972”(1) Kerala 628. One of us was a member of the Bench that decided the case. 7. The agreement dated 23rd March 1964 came up for consideration before this Court at the instance of the Commissioner for Agricultural Income-tax in Commissioner of Agricultural Income-tax, Kerala v. M/s George Varghese and Co., Kottayam I.L.R. 1972”(1) Kerala 628. One of us was a member of the Bench that decided the case. Construing the agreement this Court came to the conclusion that the contract evidenced by the agreement was a contract for the sale of the goods and upheld the conclusion reached by the Tribunal that the amounts received by M/s George Varghese and Co., for the accounting period ending 31st March 1965 relating to the year 1965-66 by slaughter tapping the rubber trees mentioned in the agreement dated 23rd March 1964 is not die agricultural income of M/s George Varghese and Co. The reasoning in the judgment in I.L.R. 1972-1 Kerala 628 is contained in paragraphs 6 and 7 of the judgment, which we may extract: "We think that in substance what the Tribunal has held is that under the agreement there has been no intention on the part of the contracting parties that the trees which were permitted to be slaughter tapped, cut and removed, should derive substance from the land and continue to afford income to the transferee, the assessee before us. The provisions in the agreement that we have read would clearly show that the definite intention was to have the trees annihilated. There was an out and out sale of the trees and considering the extent of the land on which the trees stood, 303 acres, it is quite conceivable that the removing of the trees would take considerable time and the provisions in the agreement that the assessee had three years time ,to remove them does not at all imply any intention that the trees should continue to receive nourishment from the land and afford agricultural income to the assessee. The most apt passage that we have been able to find which can be applied to the facts of the case is that contained in Marshall v. Green (1875 L.R.I.C.P. 35). The most apt passage that we have been able to find which can be applied to the facts of the case is that contained in Marshall v. Green (1875 L.R.I.C.P. 35). The passage is in these terms:- 'The principle of these decisions appears to be this, that where-ever at the time of the contract it is contemplated that the purchaser should derive a benefit from the further growth of the thing sold, from further vegetation and from the nutriment to be afforded by the land, the contract is to be considered as for an interest; but where the process of vegetation is over, or the parties agree that the thing sold shall be immediately withdrawn from the land, the land is to be considered as a mere warehouse of the thing sold, and the contract is for goods.' A reading of the agreement dated 23rd March 1964 leaves no doubt in our minds that the contract was not one for an interest in land. The intention was that the things sold, the rubber trees shall be withdrawn from the land. To adopt the words used in the above decision the land is to be considered as a mere warehouse of the thing sold. The contract was for the sale of the goods. In this view the conclusion reached by the Tribunal is correct." It is evident from the order of the Tribunal, the relevant part of which we have read, that the Tribunal, came to the conclusion that the agreement cannot be considered as one of a lease for slaughter tapping. It also found that the assessee had not received any income by way of rent. The question referred to this Court pertains to these two aspects and as far as these two questions are concerned, the second one depending on its answer on the answer to the first, we see no reason to differ from the view expressed by the Tribunal. The agreement is not an agreement for an interest in land; there is no lease involved. We found in the decision in I.L.R. 1972 (1) Kerala 628 (cited supra) that there was no intention that the trees sold should derive sustenance from the land and continue to afford income to the transferee. The answer to the two questions referred thus must, therefore, be in the affirmative, i.e., in favour of the assessee and against the department. 8. The answer to the two questions referred thus must, therefore, be in the affirmative, i.e., in favour of the assessee and against the department. 8. Counsel for the Revenue, however, argued that these two questions, as framed, do not really represent the real issues before the Tribunal and that this court has power to re-frame or re-settle the issues to bring out the real issues between the parties to the front and deal with that question. He submitted that the real question is not whether there was a lease or whether the amount received was rent; but whether the amount of Rs. 1,76,000 admittedly received by the assessee or any part of it represented agricultural income of the assessee. All the facts having been placed before the Tribunal this question does arise from the order of the Tribunal and this Court can re-settle the questions referred to this Court to bring out the issue between the parties and answer the question. In the alternative it was also contended that if for any reason, re-framing or re-settling the question is not possible, we should ask for an additional statement of the case under section 60 (5) of the Act and after receipt of the additional statement deal with the r.eal question in controversy between the Revenue and the assessee. This was the main argument that has been advanced in the case. The Tribunal has proceeded on the basis that if the amounts received was agricultural income it was received by M/s George Varghese and Co. and therefore it could not be the income of the assessee. This was the main argument that has been advanced in the case. The Tribunal has proceeded on the basis that if the amounts received was agricultural income it was received by M/s George Varghese and Co. and therefore it could not be the income of the assessee. The Tribunal did, as is clear from the order of the Tribunal, advert to the definition of ' agricultural income ' in section 2 (a) of the Act and had in mind the fact that agricultural income could be either rent or revenue derived' from the land, which is clear from the following sentence in the order : "In order to make the appellant liable for assessment on income from slaughter tapping the appellant should derive income by its own agricultural operations or received is by way of rent for lease of the land and trees for such operation." It was, however, held to be not the income of the assessee on the reasoning that: "If the purchaser had derived income by slaughter tapping it is not the appellant's income and the appellant is not concerned with what the purchaser does with the trees." 9. It is clear from the Tribunal's order that on the question whether the amount received by the assessee or part of it at least could be agricultural income other than rent, it has been held that it is not agricultural income. If an application was made before the Tribunal to refer that question to this Court under section 60 (1) of the Act we conceive that the Tribunal would have been bound to refer that question. We may add that this is the real question in the case and only on answering this question and the further question as to what part of Rs. 1,76,000 represented income, can the real controversy between the Revenue and the assessee be settled. If we are convinced that we have the power to have this question determined in these proceedings we would do so; but we have serious doubt whether we can do so either by re-framing the issues that have been framed or by calling for additional statement. 10. If we are convinced that we have the power to have this question determined in these proceedings we would do so; but we have serious doubt whether we can do so either by re-framing the issues that have been framed or by calling for additional statement. 10. There are many decisions, on the subject as to what can be done by way of re-framing or re-settling the question or what can be done by way of calling for additional statement but it is unnecessary to refer to the various decisions, because the points are fairly well settled, now and many of the points have been settled by the pronouncements of the Supreme Court. Before referring to the relevant decisions and the particular decision relied on by the Revenue we may state by way of preliminary observation that what question can be said to arise from the Tribunal's order have now been settled by the decisions of the Supreme Court, in Commissioner of Income-tax, Bombay v. Scindia Steam Navigation Co. Ltd 42 I.T.R. 589 wherein there is the following summing up by Venkatarama Aiyar, J. "The result of the above discussion may thus be summed up : (1)When a question is raised before the Tribunal and is dealt with by it, it is clearly one arising out of its order. (2) When a question of law is raised before the Tribunal but the Tribunal fails to deal with it, it must be deemed to have been dealt with by it, and is, therefore, one arising out of its order. (3) When a question is not raised before the Tribunal but the Tribunal deals with it, that will also be a question arising out of its order. (4) When a question, of law is neither raised before the Tribunal nor considered by it, it will not be a question arising out of its order notwithstanding that it may arise on the findings given by it." This summing up has been referred to with approval by a Bench of seven Judges of the Supreme Court in Keshav Mills Co., Ltd. v. Commissioner of Income-tax, Bombay 56 I.T.R. 365 11. The question as to whether any part of the sum of Rs. The question as to whether any part of the sum of Rs. 1,76,000 would be agricultural income of the assessee other that the agricultural income by way of rent was not only raised before the Tribunal ; but was dealt with by the Tribunal and it is clearly one arising from the order of the Tribunal, coming within the first item mentioned in the summary of the Supreme Court decision, which we have extracted above. This question, therefore, could have been asked to be referred, as we said, or this Court could have been moved for getting that question referred ; but having failed to do so, can the Revenue contend that we should re-frame or re-settle the question referred so as to bring out the question, at this distance of time. We think we will be going beyond our jurisdiction, because what we will be doing will not be re-framing or re-settling the question; but raising a new and different question from that framed. Such a procedure is not warranted and the unanimity of judicial opinion on the subject, we think is the same. Suffice it to refer to the commentary of Kanga (Income-tax by Kanga and Palkhivala, Vol. 1, 6th Edn. p. 1015) under section 260. The commentator says: "But it is open to the court, without raising new and different questions to re-settle or re-frame the questions formulated by the Tribunal before answering them, so as to bring out the real issue between the parties." A number of decisions have been referred in support of this statement, and this statement as such is not challenged as representing the true meaning of the judicial pronouncements on the subject. What is urged is only that the question sought now to be framed is not a new and different question; but the same question that had been referred to us; but in another form so as to bring out the real issues before us. We find ourselves unable to accede to this contention. As we have pointed out the receipts should form either one or the other of two things; rent on lease, or agricultural income coming within the expression revenue derived from land which is used for agricultural purposes. In determining whether there is rent, the question will arise as to whether there is lease. As we have pointed out the receipts should form either one or the other of two things; rent on lease, or agricultural income coming within the expression revenue derived from land which is used for agricultural purposes. In determining whether there is rent, the question will arise as to whether there is lease. But even in the absence of a lease there can be a contract for the sale of agricultural produce in the trees along with the trees. In the case before us the latex that can be obtained from the trees is the agricultural produce. That along with the timber of the trees can be sold and what is received in that case will, therefore, represent sale consideration for the sale of agricultural produce as well as consideration for the sale the timber which may be a sale of capital amount. The two questions are thus entirely different and as to whether there is one or the other will have to be established on facts. The question whether there has been any lease is entirely different from the question whether any part of the consideration for the agreement included consideration for the sale of agricultural produce. So we think that we have no jurisdiction to, re-frame or re-settle the question. 12. Dealing with the second aspect pressed by the counsel on behalf of the Revenue, unaided by any decision on the subject we would have been inclined to say that what we cannot do by way of re-framing or re-settling the question cannot be done by acting under section 60 (5) of the Act asking for an additional statement. Section 60 (5) of the Act is only for the purpose of supplying a lacuna in the case or when the conclusion of the Tribunal and its finding on material facts have not been stated in the statement in the case. More than this, this Court cannot do Under section 60 (5). The wording of the sub-section is:” "If the High Court is not satisfied that the statements in a case referred under this section are sufficient to enable it to determine the question raised thereby, the court may refer the case back to the Appellate Tribunal or the Commissioner, as the case may be, to make such additions thereto or alterations therein as the court may direct in that behalf." 13. To make such additions thereto or alterations therein are indeed wide words ; but they have not been given that wide amplitude which the words may convey tones from the context in which the words are used. These words have to be understood not only with reference to what is stated in sub-section (5) but with reference to what is stated in sub-sections 1 and 2 and the provision if so read, this Court is not entitled to refer the case back to the Appellate Tribunal to make any additions or alterations in the statement so as to bring out the real question that could have been raised or decided by the Tribunal. This is seen even from the decisions of the Supreme Court relied on by the counsel for the Revenue in New Jehangir Vakil Mills Ltd.,v. Commissioner of Income-tax, Bombay 37 I.T.R. 11 as well as Agha Abdul Jabber Khan v. Commissioner of Income-tax, M. P. 82 I.T.R. 872. In both-these decisions the Supreme Court found fault with the High Court for having called for additional statement of the cases acting under section 66 (4) of the Indian Income Tax Act, 1922, a provision corresponding to section 60 (5) of the Act. There is, however, an observation at page 19 of, which is to the following effect:” "If the question actually referred does not bring out clearly the real issue between the parties, the High Court may re-frame the questions that the matter actually agitated before the Tribunal may be raised before the High Court. " This sentence cannot be understood as enabling new or different question being raised by re-framing the question that is referred to us. It is clear from the judgment that no such thing was meant. This part of the judgment only deals with the power of the High Court to re-frame the question and it is clear from the judgment that the power to re-frame is subject to the limitation that in so re-framing, the court shall not raise a new or different question from that referred to the High Court. In fact, the decision is an authority for the proposition that the High Court has no power to raise new and different question. The sentence can only mean that there is power to re-frame to bring out clearly the real issue when re-framing does not involve the raising of any additional statement. In fact, the decision is an authority for the proposition that the High Court has no power to raise new and different question. The sentence can only mean that there is power to re-frame to bring out clearly the real issue when re-framing does not involve the raising of any additional statement. The same, we conceive, is the meaning of the observation in 82 I.T.R. 872 (cited supra) at page 875, though the wording here is wider than that used in 37 I.T.R. 11 (cited supra), in which a particular passage occurs, which is as follows: "In our opinion the High Court had no jurisdiction to raise new questions of law. The questions raised by it do not flow from the question referred to it for its opinion. The High Court's power under the Act is only to give its opinion on the questions of law referred to it by the Tribunal. It cannot take into consideration questions of law which have not been referred to it for its opinion. If the High Court thought that the question referred to it did not bring out the real point in issue it was open to it to call for a fresh statement of the case and direct the Tribunal to submit for its opinion the real question arising for decision. " The only question that arose for decision before the Supreme Court was whether the High Court was justified in re-framing the question. The power of the High Court under section 66 (4) was not the matter directly arising for consideration. We cannot understand this passage as laying down that acting under that section it is open to the High Court to call for an additional statement of the case under section 66 (4) of the Income-tax Act for raising a new and different question from that referred to the High Court. Only one more decision remains to be noticed and that is the one in Mohanlal Hiralal v. Commissioner of Income-tax, CP. and Berar 22 I.T.R. 448. With great respect we think that the court had gone beyond its jurisdiction under S. 66 (4) of the Income-tax Act, 1922 in directing the Tribunal to state the case and refer the question to the High Court. and Berar 22 I.T.R. 448. With great respect we think that the court had gone beyond its jurisdiction under S. 66 (4) of the Income-tax Act, 1922 in directing the Tribunal to state the case and refer the question to the High Court. The view adopted in this decision appears to have been sought to be justified by a reference to a decision of Chagla, C. J. in Madanlal Dharnidharka v. The Commissioner of Income-tax, Bombay 16 I.T.R. 227 wherein the learned Chief Justice has observed: "I see no reason to confine the jurisdiction of this court to such questions of law as have been argued before the Tribunal or are dealt with by the Tribunal. The section does not say so and there is no reason why we should construe the expression "arising out of such order "in a manner unwarranted by the ordinary grammatical construction of that expression. " This passage, we think with great respect, has stated the law too wide, and the statement seem to us to be against what is laid down by the Supreme Court in the two decisions that we have referred to 42 I.T.R. 589 and 56 I.T.R. 365. We are, therefore, unable to follow these decisions. 14. In the result we decline to refer the question and to call for an additional statement raising new questions. We answer the two questions in the affirmative, i.e., in favour of the assessee and against the department. We direct the parties to bear their respective costs. 15. A copy of this judgment, under the seal of the Court and signature of the Registrar, will be sent to the Agricultural Income-tax Appellate Tribunal, Trivandrum.