Exemption to State Cricket Association cannot be denied for providing stadium to conduct matches

Whether the activity of conducting one-day matches_‘T-20 matches and Indian Premier League matches by Tamil Nadu Cricket Association would amount to doing business or trade?

It is the case of the Revenue that the assessee-society is conducting or organizing T-20_‘ one-day matches or Indian Premier League matches. In fact_‘ BCCI  the parent organization which is a national body in India_‘ is organizing and conducting the matches. The assessee-society_‘ being a member of BCCI_‘ hosts the matches which are conducted by BCCI. For the purpose of meeting its expenditure_‘ the BCCI allocates funds from the revenue it collected from advertisement and other sources. The assessee-society is allowed to sell tickets to the cricket viewers. No doubt_‘ the players of Indian Premier League are sold in public auction for very huge amount. But the question is who is conducting and who is auctioning_‘ whether the assessee-society or BCCI? In fact_‘ BCCI conducts the public auction for selling premier players at a huge premium rate. In fact_‘ the BCCI collects the money. The role of the assessee-society is only to provide stadium for conducting matches. Other than that_‘ the assessee-society has no role in conducting the international matches and Indian Premier League matches.