Spouse income clubbing under section 64(1)(i) raised no substantial question of law for reference.

Section 64(1)(i) of the Income-tax Act requires inclusion in an individual's total income of income arising directly or indirectly to the spouse from membership in a firm where the individual is a partner. The Gauhati HC noted that the language of the provision was clear and self-evident, so no further interpretive issue arose. On that basis, the Tribunal was justified in treating the proposed issue as not raising a substantial question of law under section 256(2), and the reference petitions were rejected.

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Issues: Whether any referable question of law arose under section 256(2) of the Income-tax Act, 1961 on the inclusion of the spouse's share income under section 64(1)(i) of the Income-tax Act, 1961.

Analysis: The dispute turned on the construction of section 64(1)(i), which provides for inclusion in the total income of an individual of income arising directly or indirectly to the spouse from membership in a firm in which the individual is a partner. The Court held that the provision was clear and self-evident and did not require further interpretation. On that basis, the Tribunal was justified in treating the proposed question as not giving rise to any substantial question of law warranting a reference.

Conclusion: No question of law arose for reference, and the petitions seeking a reference were rejected.

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