CA
117 Points
Joined June 2010
Stipend, prima facie, should be treated as a scholarship and should be exempt,
since Sec. 10(16) exempts all ``scholarships granted to meet the cost of
education''. In CIT v V. K. Balachandran (1984) 147 ITR 4 (Mad), the amount
received as grant-in-aid and other fringe benefits from a foreign university,
though in the nature of salary, was found to be still exempt under Sec.
10(16). A similar medical scholarship from a foreign university during
training programmes was held to be exempt under Sec. 10(16) in A. Ratnakar Rao
v Addl. CIT (1981) 128 ITR 527 (Kar) and Dr. V. Mahadev v CIT (1990) 184 ITR
533 (Mad). In the latter case, it was held that since scholarship is exempt,
even if there be any savings therefrom, it need not be taxable. The Board has
clarified from time to time that various scholarships under different schemes
as research fellowships granted by the Government are not taxable, but such
clarifications are not necessary for every scholarship.