( 1 ) THESE three references at the instance of the assessce, pertain to the assessment years 1958-59, 1960-60 and 1961-62. The common question of law, referred by the Tribunal for our opinion, is :

"whether on the facts and in the eimcumstances of the case. the payments of Rs. 5,67,000. Rs. 5,000 and Rs. 5,000 are permissible deductions under Section 10 (2) (xv)of the Indian Income-tax Act, 1922 for the assessment years 1958-59, 1960-61 and 1961-62?"

( 2 ) THE assessee-company runs a manufacturing unit. During the assessment, year 1958-59. it paid a sum of Rs. 5,67,000 to the Indian National Congress. It also made payments to the Indian National Congress of Rs, 5000 in each of the assessment years 1960-61 and 1961-62.

( 3 ) THE asscssee claimed these amounts as permissible deductions under Section 10 (2) (xv) of the Indian Income-tax Act. 1922. The asscssee contended before the Income-tax Officer that the donation to the Indian National Congress was incurred wholly and exclusively for the purpose of its business. The Income-tax Officer did not accept this contention, and disallowed the deductions.

( 4 ) ON appeal by the assessee. the Appellate Assistant Commissioner c