2001 (2) TMI 878

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..... against the order of the DCIT (Appeals) dated 28-8-1996 and the only issue is as to whether Assessing Officer was justified in disallowing deduction on account of donation claimed under section 80G by way of prima facie adjustment under section 143(1)( a ). 2. Assessee filed return on 1-9-1993 declaring total income at Rs. 82,420. Disallowance of an amount of Rs. 9,936 was made by the Assess .....

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..... t in any case, the issue is not amenable to be the subject matter of prima facie adjustment under section 143(1)( a ). 4. On the other hand, ld. Deptl. Representative produced a copy of receipt issued by Vasavi Academy of Education dated 15-6-1992, on the back of which the following is, what is written. "Towards donation for seat to Mech. Engg. for Sandeep V. Nagda Donation details .....

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..... defined either under section 80G or under the Income-tax Act. But the generic and the natural meaning of the word donation is that a person gives money to another without any material return, voluntarily and without any consideration the sum so given is donation. In the instant case, as per the description of the noting made on the back of the receipt, it is clear that it was not a gratitious pa .....

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