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    <title>2026 (5) TMI 1320 - ITAT MUMBAI</title>
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    <description>Scholarship support granted in India to Indian students for overseas education was treated as application of income for charitable purposes in India, because the relevant test is the situs of application of funds and the education object remained directed to Indian beneficiaries. On that basis, refusal of registration under section 12AB could not stand, as it rested on the mistaken view that the expenditure amounted to application of income outside India. The rejection of approval under section 80G also failed, since it was entirely consequential upon the registration refusal and once that basis disappeared, the statutory bar no longer applied.</description>
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      <description>Scholarship support granted in India to Indian students for overseas education was treated as application of income for charitable purposes in India, because the relevant test is the situs of application of funds and the education object remained directed to Indian beneficiaries. On that basis, refusal of registration under section 12AB could not stand, as it rested on the mistaken view that the expenditure amounted to application of income outside India. The rejection of approval under section 80G also failed, since it was entirely consequential upon the registration refusal and once that basis disappeared, the statutory bar no longer applied.</description>
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