During the previous years relevant to the assessment years 2011-12 to 2014-15 the assessee made payments towards subgrant to the University of Texas with its principal place of business at Houston, Texas, U. S. A. The assessee was denied the benefit of sections 11 and 12 because the University of Texas, not being registered for purposes of foreign contributions, transfer of funds to that entity attracted the provisions of section 11(1)(c) of the Income-tax Act, 1961, rejecting the assessee’s contention that the funds had been spent out of the funds received earlier from the National Institute of Health which had already been included in the receipts side of the income and expenditure account. The Commissioner (Appeals) categorically gave the finding that for the assessment years 2011-12, 2012-13, 2013-14 and 2014-15 only the portion of income to the extent not applied in India will not be eligible for exemption. Order of CIT(A) is affirmed.   (AY. 2010-11 to 2014-15)