Dismissing the appeal of the revenue the Tribunal held that,exemption cannot be denied merely on ground that it was receiving fees from foreigner students in foreign exchange abroad by way of an arrangement with an educational organisation abroad.The provisions of section 10(22) for claiming exemption provides that the requirement is that the university or the educational institute must exist solely for educational purposes in India in other words, the recipient of the income must have the character of an educational institute in India and its character outside India or it being a part of university existing outside India is not relevant for deciding whether its income would be exempt under section 10(22) or not. ( AY.1998-99)