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4. Mr. Jayaraman, learned counsel for the Revenue, submitted that the Tribunal had enlarged the scope of the exclusion provision in s. 10(16) when they held that the expression "to meet the cost of education" must be construed liberally. We do not think so. In our view the words "to meet the cost of education" are not a limiting factor, but may be regarded even as surplus age. By scholarship, as ordinarily understood, we mean anything which makes education free of charge, or at a concessional rate of fees, as when we say that someone is studying under a half-scholarship.

5. In s. 10(16), however, scholarship is not used in that sense of something in educational opportunity which is given free. The basic postulate of a scholarship in clause (16) as earlier mentioned is that is an income receipt. Nevertheless it is excluded from the total income by being brought under s. 10. The view of the income-tax statute of a scholarship therefore, differs from the popular, or dictionary, view of a "scholarship". Whereas under the popular view, scholarship is education made available gratis, the sense in which the same expression is used in the I.T. Act is positive payment made to a scholar for pursuit of his education. If scholarship is made free, it would not naturally come within the ambit of s. 10(16). In the sense of payment made for studies, scholarship necessarily means some payment to meet the cost of education, the payment being made to the person pursing the education and incurring the cost thereof.