( 1 ) ). THIS petition under Article 226 of the Constitution of India, is filed by the Trustees of the Gujarat Law Society Karmachari Kalyan Nidhi, Ahmedabad.

( 2 ) THE short facts leading to the present proceedings are as under :- respondent-Commissioner of Income Tax (hereinafter referred to as "c. I. T. ") considered the application dated 21. 7. 1981 of the Gujarat Law Society Karmachari Kalyan Nidhi (hereinafter referred to as "the Trust") submitted under Section 12a (a) of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), and vide letter dated 21. 4. 1982 (Annexure `e) informed the said trust that the same has been registered under Section 12a (a) of the Act. For the assessment year 1985-86, the Trust was denied the exemption and benefit under Section 80g (5) of the Act by an order dated 10. 2. 1989 by the Income Tax Officer (hereinafter referred to as "i. T. O. " ). Notices dated 10. 2. 1989 were issued by the I. T. O. under Section 148 of the Act for the assessment year 1984-85, and under Section 274 read with Sections 273 (2) (b), 271 (1) (a) and 271 (1) (c) of the Act for the assessment year 1985-86. Respondents, though served, have filed no r