( 1 ) THE following questions are involved in this reference under Section 256 (2) of the Income-tax Act, 1961 :"1. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the period of limitation under Section 154 of the Income-tax Act, 1961, should be computed from the order of the Income-tax Officer under Section 49a of the Indian Income-tax Act, 1922, dated, February 22, 1961, and not from his order dated September 4, 1963, under Section 154 of the Income-tax Act, 1961, in respect of which rectification of mistake was applied for and in dismissing the appeal on that ground ? Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the period of limitation under Section 154 of the Income-tax Act, 1961, should be computed from the order of the Income-tax Officer under Section 49a of the Indian Income-tax Act, 1922, dated March 30, 1961, and not from his order dated September 4, 1963, under Section 154 of the Income-tax Act, 1961, in respect of which rectification of mistake was applied for and in dismissing the appeal on that ground?"

( 2 ) THE assessment years invo