1987 (3) TMI 81

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..... ised by learned counsel for the assessee. Sri B. N. Bhatnagar, learned counsel for the assessee, submitted that in view of the fact that notice of refusal by the Tribunal under section 256(1) of the Income-tax Act was served on the Commissioner of Income-tax on June 25, 1986, the application filed by it on January 1, 1987, was barred by limitation by six days. It was urged that the period prescrib .....

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..... n to mean a period of 30 days. The contextual setting of section 27l(1) is entirely distinct and different from section 256(2). There is nothing in the context of section 256(2) to warrant the meaning assigned to the word " month " in the aforesaid decision to an application filed under section 256(2) of the Act. In our opinion, the reference to six months in section 256(2) is to six calendar mont .....

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