In a list, does 'counting from' an item includes the item itself?

For me "counting six down from the top" would imply choosing the sixth item on the list since the first item "is at the top" of the list rather than "forms" the top of the list. In other words the list, in one sense, has existence independently of the items in it and if the items are reordered or the first item is deleted the top of the list is still in the same place but a different item occupies that position.

In this sense it is like a queue for a checkout where the head of the queue is always in the same place but the person at the head of the queue keeps changing as customers are served.

Having said that there is some ambiguity in the instruction and I would have preferred them to say "select the sixth item on the list" which has only one possible interpretation.