ADIT (IT)-3(1), MUMBAI vs. M/S. GLOBAL CRICKET CORPORATION PTE. LTD., MUMBAI

ITA 3130/MUM/2006Status: DisposedITAT Mumbai14 December 2022AY 2002-200395 pages
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What did the Tribunal hold?

The Tribunal held that the assessee was entitled to the benefits of the DTAA for both assessment years. It ruled that sponsorship fees were not taxable as royalties in India, and a portion of license fees from SET was taxable as royalty.

What were the facts?

The appeals concerned the taxability of income earned by Global Cricket Corporation Pte Ltd. from various Indian entities for assessment years 2002-03 and 2003-04. The core dispute revolved around the applicability of the India-Singapore Double Taxation Avoidance Agreement (DTAA).

What were the issues?

Whether income from sponsorship and license fees received by a Singaporean company from Indian entities is taxable in India, and if the benefits of the India-Singapore DTAA are applicable.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 234B

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Cases cited in this judgment(27)Show list

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Heard together (2 matters)

CO No. 324/MUM/2006
CO No. 160/Mum/2009

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IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ADIT (IT) 3(1), Scindia House, R. No. 132, 1st Floor, N.M. Road, Mumbai - 400038 ……………… Appellant Global Cricket Corporation Pte Ltd., Vs C/o S. R. Batliboi & Co. 18th Floor, Express Towers, Nariman Point, Mumbai-400021 [PAN: AABCG7951L] ……………. Respondent CO No. 324/MUM/2006 (Assessment Year: 2002-2003) Arising out of ITA No. 3130/Mum/2006) Global Cricket Corporation Pte Ltd., C/o S. R. Batliboi & Co. 18th Floor, Express Towers, Nariman Point, Mumbai-400021 [PAN: AABCG7951L] ……………… Appellant Assistant Director of Income-Tax, (International Taxation)-3(1), Vs Scindia House, Room No. 132, 1st Floor, N M Road, Mumbai – 400038 ……………. Respondent Global Cricket Corporation Pte Limited, C/o Star India Private Limited, Star House, Off DR E Moses Road, Mahalaxmi, Mumbai - 400011 [PAN: AABCG7951L] ……………… Appellant Assistant Director of Income-Tax, Vs (International Taxation)-3(1), Scindia House, Ballard Pier, Mumbai - 400038 ……………. Respondent

ITA. No. 3135 & 3130/Mum/2006 & CO No. 324/Mum/2006 ITA No. 1510 & 1444/Mum/2009 & CO No. 160/Mum/2009 Assessment Yea

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