1994 (8) TMI 22

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..... t, 1961, seeking our opinion on the following question of law: " Whether the Tribunal was right in law in holding that the applicant is not entitled for relief under section 80G of the Income-tax Act in respect of donation of Rs. 20,000 each made by it to S. Rm. Ct. M. Tiruppani Trust for the assessment years 1969-70 and 1970-71 ? " There is no dispute that the assessee donated the amount ment .....

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..... d upheld the order of the Income-tax Officer. Thereafter, the assessee sought for a reference which has been made. The submission of learned counsel for the assessee is that section 80G of the Act is independent of sections 11 and 12A of the Act and, therefore, considerations of those sections should not influence the decision in the instant case. There appears to be no difficulty in accepting t .....

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..... name of the trust in question itself indicates that it belongs to a particular religious community. The object of the trust includes not only charitable purposes but also religious purposes like renovating old Hindu temples or establishing and maintaining Pasumadam and Nandavanam for the use of the Hindu temples. These would, therefore, sufficiently indicate that sub-section (5) of this provision .....

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