In a major relief to the Legendary Cricket Sachin Tendulkar, the Customs, Excise & Service Tax Appellate Tribunal (CESTAT), Mumbai has held that IPL match fees are not taxable as business support service.
A Division Bench comprising Judicial Member S.K. Mohanty and Technical Member M.M. Parthiban observed that the issue was no longer res integra and had been settled by several previous rulings involving other IPL players and franchises.
The Bench cited earlier decisions in cases such as Sourav Ganguly, Karn Sharma, Piyush Chawla, Yusuf Pathan, Anil Kumble, and Yuvraj Singh Bundhel, where similar service tax demands were quashed. These rulings consistently held that a player’s remuneration for participating in cricket matches is a non-taxable sports activity, not a business support service.
Referring to the Tribunal’s 2023 ruling in Knight Riders Sports Pvt. Ltd., the Bench reiterated that player agreements are primarily for playing cricket, and promotional obligations are incidental. In the absence of any clear mechanism to segregate non-taxable sporting services from taxable promotional elements, the entire consideration cannot be subjected to tax.
The case stemmed from an audit observation that payments were made to Tendulkar by Indiawin Sports Pvt. Ltd., a franchisee under the BCCI-IPL consortium, for the seasons 2008–09 to 2011–12, amounted to taxable services under the category of Business Support Service (BSS). The department contended that Tendulkar had failed to pay service tax on such income.
A Show Cause Notice issued in March 2013 proposed recovery of ₹1.23 crore, alleging that the cricketer’s activities — including wearing franchise-branded apparel and participating in endorsement events — amounted to business support to the franchise.
However, the Commissioner of Service Tax-IV, Mumbai dropped 90% of the proposed demand, holding that the services rendered by a player in relation to participating in cricket matches could not be treated as taxable under BSS. The Commissioner only confirmed a nominal demand of ₹12.5 lakh, representing 10% of the contracted amount retained by the player even if he did not play any match — a portion considered as promotional in nature.
Dissatisfied, the department filed an appeal before the Tribunal arguing that the entire amount paid to the player should be taxable since his activities, including media appearances and brand visibility, supported the business interests of the franchisee.
Concluding that there was no infirmity in the Commissioner’s order, CESTAT dismissed the department’s appeal and disposed of the cross-objection filed by the cricketer.
Case Details
Case Title: Commissioner of Service Tax-IV, Mumbai Versus Sachin Tendulkar
Case No.: Service Tax Cross Objection No. 91136 of 2016 In Service Tax Appeal No. 86880 of 2016
Date: 24.04.2025
Counsel For Appellant: AR Dhananjay Dahiwale
Counsel For Respondent: Advocate Bharat Raichandani
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