https://www.taxtmi.com/caselaws?id=787162 Tied project grants contractually earmarked for foreign co-investigators may constitute diversion of income by overriding title rather than application of income outside India. Amounts attributable to overseas collaborators are therefore excluded from the charitable institution's income for exemption purposes, leaving only the net grant retained for application in India. Disallowance for benefit to specified persons requires proof that the overseas recipient falls within the statutory category of interested persons and that a direct or indirect benefit arose. For the relevant assessment years, any disallowance is limited to the actual shortfall in the required charitable application; the identified shortfall arose only in assessment year 2010-11. en-us Wed, 25 Feb 2026 00:00:00 +0530 Thu, 26 Feb 2026 15:41:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787162 Tied project grants contractually earmarked for foreign co-investigators may constitute diversion of income by overriding title rather than application of income outside India. Amounts attributable to overseas collaborators are therefore excluded from the charitable institution's income for exemption purposes, leaving only the net grant retained for application in India. Disallowance for benefit to specified persons requires proof that the overseas recipient falls within the statutory category of interested persons and that a direct or indirect benefit arose. For the relevant assessment years, any disallowance is limited to the actual shortfall in the required charitable application; the identified shortfall arose only in assessment year 2010-11. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787162