https://www.taxtmi.com/caselaws?id=780197 ITAT CHENNAI - AT allowed the trust's claim under section 11(1)(a), holding payments to a foreign institute for examination, licence and exemption fees (and related foreign exchange loss) constitute application of income in India where materials and services are used exclusively for Indian students and books are imported tangible assets. The tribunal distinguished NASSCOM, relied on an earlier binding 12AA finding that the activities qualify as "education," and found the AO erred in disallowing the expenditure; the disallowance is deleted and the ground is allowed. en-us Mon, 29 Sep 2025 00:00:00 +0530 Sat, 25 Oct 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780197 ITAT CHENNAI - AT allowed the trust's claim under section 11(1)(a), holding payments to a foreign institute for examination, licence and exemption fees (and related foreign exchange loss) constitute application of income in India where materials and services are used exclusively for Indian students and books are imported tangible assets. The tribunal distinguished NASSCOM, relied on an earlier binding 12AA finding that the activities qualify as "education," and found the AO erred in disallowing the expenditure; the disallowance is deleted and the ground is allowed. Case-Laws Income Tax Mon, 29 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780197