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Issues: Whether the questions sought to be referred under section 256(2) of the Income-tax Act, 1961, gave rise to questions of law requiring reference to the High Court.
Analysis: The Revenue sought reference on the characterisation of interest income for two assessment years. The Court found that the proposed questions were questions of law arising from the Tribunal's order, and therefore the statutory requirement for making a reference was satisfied.
Outcome: The Tribunal was directed to draw up the statement of case and refer the questions to the High Court for opinion.
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