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Issues: Whether deduction under section 80G of the Income-tax Act, 1961 was allowable in respect of donations made in kind.
Analysis: Section 80G(2)(a) was construed as contemplating only a cash amount of money as donation and not a transfer of property or other donation in kind. The question stood answered by the Supreme Court, which settled the conflict of view among High Courts by holding that donations in kind do not qualify for deduction under the provision.
Conclusion: The assessee was not entitled to deduction under section 80G of the Income-tax Act, 1961 for donations made in kind, and the reference was answered in favour of the Revenue.
Ratio Decidendi: Deduction under section 80G is confined to cash donations and does not extend to donations made in kind.