1982 (4) TMI 92

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..... ssessment years 1978-79 and 1979-80, respectively, from the National Institute of Health (NIH), Bethesda, Maryland, USA. He also received $ 1,025 and $ 600 in the said two years, respectively, for giving lectures and also received royalty of $ 505 in the calendar year 1978. The foreign income was shown in the returns for these two years. No claim for exemption under section 10(16) was made before .....

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..... e ratio laid down in the decision of the Karnataka High Court reported in A. Ratnakar Rao v. Addl. CIT does not apply. Alternatively, he submitted that at least the remuneration received for giving lectures and the royalty amount are taxable and they are not exempt under section 10(16). The learned counsel for the assessee supported the orders of the appellate authority. He urged that the assessee .....

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..... the primary purpose of that was to further the education and training of the fellow rather than to benefit the grantor. It further states that the stipend payments do not represent compensation for past, present or future employment services nor do they represent remuneration for services subject to the direction or supervision of the grantor. Thus, the amount received by the assessee is not in t .....

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