9911796707
TMI Blog2024 (9) TMI 212X X X X Extracts X X X X X X X X Extracts X X X X ..... present assessee which is representing the country under the aegis of the Government in amateur international sports events. CIT(A) has specifically observed on facts of the case that in regard to participation in Rio Olympics games in 2016 the expenditure incurred is more than the sponsorship amounts received. The sponsorship agreements are not long-term contracts and there was no bidding process. Arranging these sponsorship contracts is in itself a great task for the assessee as the sponsors are paying out of their profits for motivating the assessee and the sportspersons of the country in participating in international events. Neither the sponsor nor the assessee can be attributed any profit motive from the outcome of these sponsorship ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 22. 2. the appellant craves leave to add, alter, amend, append or delete any of above grounds. 3. Heard and perused the record. 4. On hearing both the sides, it comes up that the assessee is an organization registered under the Societies Registration Act, 1860 and is also registered u/s 12A of the Act. It is an apex sports body in India representing the country and is a member of International Olympic Association. The Associations of different disciplines in sports in India are members/affiliated to IOA. The activities of the association includes organizing sports activities under the aegis of Ministry of Youth Affairs and Sports, Government of India and International Olympic Association. Utilisation certificates were regularly submitted by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are commercial in nature and accordingly held that the income from such receipts constituting its major commercial income is more than 20% of the total receipts. Therefore, the assessee is hit by the second proviso to section 2(15) of the Act and, hence not eligible for benefit of exemption u/s 11 and 12 of the Act and, accordingly, assessed assessee s income as normal income without allowing deduction u/s 11 of the Act. 5. The CIT(A), however, considered the fact that on the same grounds additions were made in AYs 2019-20, 2011-12, 2013-14 and 2014-15 and the assessee preferred an appeal before the CIT(A) wherein the appeals were allowed and, thereafter, the Department carried the matter before the Tribunal wherein the Department s appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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