(1) THIS appeal by certificate under S. 261 of the Income Tax Act, 1961 and under Article 133 of the Constitution is directed against the judgment of a division bench of the High court of Kerala dated 11/04/1975 holding that the appellant was not entitled to benefit of Section 80-G of the Income Tax Act, 1961 in respect of the donations made by him in the previous years,

(2) THE appellant is an assessee under the Income Tax Act, he donated equity shares of Nirlon Synthetic Fibres and Chemicals Ltd. having face value of Rs. 12,50,000.00 to each of two trusts, namely, H.H. Maharani Setu Parvati Bayi Trust and H.H. Princess Lakshmi Bayi Trust. The total donation, according to the assessee, amounted to Rs. 25,00,000.00 . In the assessment year 1968-69, the assessee claimed exemption under Section 80-G of the Act in respect of the aforesaid donations made by him to Charitable Trusts. The Income Tax Officer rejected the claim. On appeal the Appellate Assistant Commissioner directed the Income Tax Officer to call for the relevant receipts and if satisfied with the admissibility of the deduction claimed to grant the deduction according to law. The revenue preferred appeal be