https://www.taxtmi.com/caselaws?id=787162 The note addresses whether NIH project sub-grants remitted to a US university are applications of income for a tied charitable project or disallowable as application outside India, and whether such remittances attract disallowance as payments to specified persons. It clarifies that where grant funds are contractually earmarked for foreign co investigators, those amounts constitute diversion by overriding title and are excluded from the assessee's free income for exemption purposes; conversely, disallowance under the specified person rule requires factual establishment that the foreign recipient falls within the specified person description. The remittance shortfall was limited to the actual deficiency for one assessment year; other years were allowed. 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 The note addresses whether NIH project sub-grants remitted to a US university are applications of income for a tied charitable project or disallowable as application outside India, and whether such remittances attract disallowance as payments to specified persons. It clarifies that where grant funds are contractually earmarked for foreign co investigators, those amounts constitute diversion by overriding title and are excluded from the assessee's free income for exemption purposes; conversely, disallowance under the specified person rule requires factual establishment that the foreign recipient falls within the specified person description. The remittance shortfall was limited to the actual deficiency for one assessment year; other years were allowed. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787162