https://www.taxtmi.com/caselaws?id=38046 A procedural certificate requirement under rule 191(2) was treated as subordinate to the substantive statutory right to seek reference under section 256(2), so omission of the certificate did not justify dismissal where the statute itself imposed no such condition or penalty. The text also notes that questions arising from the chartered accountant's authority and the addition of income were considered suitable for reference: questions 1 and 3 were held to be questions of law fit for the High Court, while question 2 was not considered necessary for determination. The stated principle is that procedural compliance cannot override a statutory reference right unless the statute expressly makes it mandatory. en-us Tue, 05 Jul 1977 00:00:00 +0530 Fri, 02 Apr 2010 17:22:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38046 A procedural certificate requirement under rule 191(2) was treated as subordinate to the substantive statutory right to seek reference under section 256(2), so omission of the certificate did not justify dismissal where the statute itself imposed no such condition or penalty. The text also notes that questions arising from the chartered accountant's authority and the addition of income were considered suitable for reference: questions 1 and 3 were held to be questions of law fit for the High Court, while question 2 was not considered necessary for determination. The stated principle is that procedural compliance cannot override a statutory reference right unless the statute expressly makes it mandatory. Case-Laws Income Tax Tue, 05 Jul 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38046