Computation of six months under income-tax reference provisions and whether proposed questions arise from the Tribunal order.

The article examines whether the six-month period under section 256(2) of the Income-tax Act, 1961 should be computed as six calendar months or as 180 days, and whether the Revenue's proposed questions truly arose from the Tribunal's order so as to warrant reference to the High Court. It focuses on the legal method of computing time under the provision and the threshold for maintainability of a reference, without supplying a final adjudicatory outcome in the available text.

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Issues: (i) Whether the six months' period under section 256(2) of the Income-tax Act, 1961 is to be computed as six calendar months or as 180 days. (ii) Whether the questions proposed by the Revenue arose out of the Tribunal's order for reference to the High Court.

Issue (i): Whether the six months' period under section 256(2) of the Income-tax Act, 1961 is to be computed as six calendar months or as 180 days.

Analysis: The word

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