Maharashtra Cricket Association vs Income Tax Dept: ITAT Orders Fresh Review



Quick Summary
The Income Tax Appellate Tribunal (ITAT) has sent back the Maharashtra Cricket Association's (MCA) tax exemption case for AY 2010-11 for a new review. The ITAT noted that the initial exemption granted by the CIT(A) did not consider the Supreme Court's crucial AUDA judgment, which highlighted the commercial nature of state cricket associations. This ruling necessitates a fresh look at MCA's income, particularly grants and interest, to ensure consistency with the Supreme Court's findings.

Pune ITAT has set aside the exemption granted to the Maharashtra Cricket Association (MCA) under Sections 11 & 12 for AY 2010-11, and remanded the matter for fresh adjudication in light of the Supreme Court's AUDA judgment. 

Here is what exactly happened

MCA, a trust registered under Section 12A since 1991, had declared NIL income, claiming it had applied its income for charitable purposes. The AO, however, wasn't convinced. He denied exemption by citing the cancellation of MCA's 12A registration, and argued that their activities were commercial in nature post the amendment to Section 2(15). He taxed grants received from BCCI, interest income, and other receipts, assessing MCA's income at ₹25.66 crore.

MCA vs Income Tax: ITAT Orders Fresh Review

The first appeal swung in MCA's favour. The CIT(A)/NFAC restored the exemption, treating BCCI grants as capital receipts and held that MCA was still registered under 12A, as restored by the ITAT. He accepted that income was applied for charitable purposes.

But the Revenue wasn't ready to walk back to the pavilion just yet. In its appeal, it highlighted that the CIT(A) failed to consider the landmark AUDA ruling. delivered by the Supreme Court in October 2022. In that judgment, the SC held that State Cricket Associations operate commercially-with large revenue streams from media and broadcast rights via BCCI, and that such receipts must be carefully scrutinized.

 

Interestingly, although the AUDA ruling predated the CIT(A)'s order by nearly a month, it was never referred to in the decision.

The ITAT noted that similar issues in MCA's own cases for AYs 2011-12 & 2012-13 were already sent back for re-evaluation.

 

So, for consistency and in light of the SC verdict, the Tribunal remanded the case back to CIT(A) with clear directions: reconsider the case afresh, factor in AUDA, and give both parties a fair chance to present their case.

Official copy of the judgment has been attached 

FAQ :

The Pune ITAT has set aside the exemption granted to the MCA for AY 2010-11 and remanded the matter for a fresh adjudication.

The AO denied exemption citing the cancellation of MCA's 12A registration and argued their activities were commercial after an amendment to Section 2(15).

The CIT(A)/NFAC restored the exemption, treating BCCI grants as capital receipts and accepting that MCA's income was applied for charitable purposes.

The Supreme Court's AUDA judgment held that State Cricket Associations operate commercially, with significant revenue streams that require careful scrutiny. This ruling was not considered in the CIT(A)'s initial decision.

The ITAT directed the CIT(A) to reconsider the case afresh, factor in the AUDA judgment, and provide both parties a fair opportunity to present their arguments.




About the Author

Financial Analyst at Amazon

Dynamic and detail-oriented Chartered Accountancy professional with expertise in Direct Taxation, Income Tax Litigation, and Tax Compliance. I bring over three years of comprehensive experience through my articleship at Kirtane Pandit LLP, Pune, where I excelled in:??Managing scrutiny assessments under the Income Tax ... Read more

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