IN THE HIGH COURT OF JUDICATURE AT BOMBAY IN THE HIGH COURT OF JUDICATURE AT BOMBAY IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION ORDINARY ORIGINAL CIVIL JURISDICTION ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX REFERENCE NO. 15 OF 1990 INCOME TAX REFERENCE NO. 15 OF 1990 INCOME TAX REFERENCE NO. 15 OF 1990 The Commissioner of Income-tax, Bombay City-VI, Bombay. ...Applicant V/s. The Dharamsi Morarji Chemicals Co. ...Respondent Mr.Ashok Kotangle for Applicant. Mr.V.B. Patel for Respondent. CORAM : CORAM : CORAM : V.C. DAGA AND V.C. DAGA AND V.C. DAGA AND A.S. AGUIAR, JJ. A.S. AGUIAR, JJ. A.S. AGUIAR, JJ. DATED : JULY 5, 2005. DATED : JULY 5, 2005. DATED : JULY 5, 2005. P.C. :- P.C. :- P.C. :- . By this reference under Section 256(1) of the Income-tax Act, 1961, the Income Tax Appellate Tribunal has referred the following questions of law for the opinion of this Court :- "1. Whether, on the facts and in the circumstances of the case, the disallowance under Rule 6D should be made on all the tours taken together during the previous year and not on per visit per employee basis ? 2. Whether on the facts and in the - 2 - circumstances of the case, the ceiling limit of sub-section (4) of sec.80G applies to the amount of actual deduction as specified in sec.80-G (1) and not to the qualifying amount of donations taken together?" . The above question no.1 is covered by the Judgment of this Court in the case of Commissioner of Commissioner of Commissioner of Income Tax V/s. Aorow India Ltd. (1998) 229 ITR 325. Income Tax V/s. Aorow India Ltd. (1998) 229 ITR 325. Income Tax V/s. Aorow India Ltd. (1998) 229 ITR 325. Accordingly, same is answered in favour of the revenue and against the assessee. . So far as question no.2 is concerned, the same has also been answered by this Court in the case of Commissioner of Income Tax V/s. New Shorrock Spg. and Commissioner of Income Tax V/s. New Shorrock Spg. and Commissioner of Income Tax V/s. New Shorrock Spg. and Mfg.Co.Ltd. (1995) 212 ITR 355 Mfg.Co.Ltd. (1995) 212 ITR 355 Mfg.Co.Ltd. (1995) 212 ITR 355 in favour of revenue and against the assessee. Accordingly, both the questions are answered and the reference stands disposed of with no order as to costs. (A.S. AGUIAR, J.) (V.C. DAGA, J.) (A.S. AGUIAR, J.) (V.C. DAGA, J.) (A.S. AGUIAR, J.) (V.C. DAGA, J.)