AJIT K. SENGUPTA, J.

( 1 ) IN this reference under Section 256 (1) of the Income-tax Act, 1961, the Tribunal has referred the following three questions :"1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in allowing the expenses relating to food, tiffin and salary paid to guest house staff and depreciation on assets used in the assessee's guest houses

( 2 ) WHETHER, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in treating the contribution to the Molasses Storage and Maintenance Reserve created under the Uttar Pradesh Sheera Niyatran (Sansodhan) Adesh, 1974, as a revenue expenditure ?

( 3 ) WHETHER, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the assessee-company was entitled to deduction under Section 80g in respect of the donation to Vishwa Mangal Trust ?" 2. Shortly stated, the facts are that the assessment year involved is 1978-79. The assessee-company claimed deduction for expenses incurred for providing food, tea, tiffin, etc. , to visitors and customers who stayed in its tour guest houses at

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