S. P. Bharucha, J. - (1.) A Division Bench of the Calcutta High Court answered the following question in the negative and in favour of the Revenue:"Whether on the facts and in the circumstances of the case the Appellate Tribunal was justified in holding that the assessee was entitled to the relief under Section 80-G on the donations paid to Vishwa Mangal Trust -
(2.) The assessee is in appeal by certificate.
(3.) We are concerned in the first appeal with the Assessment Year 1973-74, the relevant previous year having ended on 30th June, 1972. The assessee had made a donation of Rs. 25,000/- to the Vishwa Mangal Trust (hereinafter called the Trust). The assessee claimed a deduction under Section 80-G in respect of that donation. The claim was allowed by the Income-tax Officer on 27th December, 1976. The assessment was then re-opened under Section 147 (b) of the Income- tax Act and on 30th December, 1977 the Income-tax Officer disallowed the claim. The Appellate Assistant Commissioner dismissed the assessees appeal. The Income-tax Appellate Tribunal allowed the appeal preferred by the assessee against the order of the Appellate Assistant Commissioner. Thereafter it referred the question set out above to the High Court. The High Court reversed the view of the Tribunal.;