Oxford and Cambridge Society of India Vs CIT (Exemption) (ITAT Delhi)
Material Facts
The assessee, a society registered since 1982 comprising alumni of Oxford and Cambridge Universities, awards merit scholarships to Indian students pursuing postgraduate studies at those universities. The CIT(E), by orders dated 27.03.2026, rejected the assessee’s application for registration under Section 12AB and consequently rejected registration under Section 80G.
The CIT(E) held that the scholarships were ultimately utilised outside India in alleged violation of Section 11(1)(c), questioned the selection process, observed that scholarships were not strictly based on financial hardship, and noted the absence of follow-up with scholarship recipients.
Parties’ Submissions
The assessee submitted that scholarship funds were disbursed in India, in Indian currency, directly to students or their parents/guardians through Indian bank accounts. It contended that no money was remitted to any foreign university or institution. It also submitted that both merit and financial background were considered while selecting candidates and explained that privacy and data protection laws prevented foreign universities from sharing graduates’ details. The Society nevertheless maintained outreach through alumni forums, social media and voluntary engagement.
The Revenue supported the CIT(E)’s order, contending that the funds were ultimately utilised outside India.
Tribunal’s Findings
The Tribunal identified the principal issue as whether scholarships paid in India to Indian students for studies abroad constituted application of income outside India under Section 11(1)(c).
