JUDGMENT :

UDAY UMESH LALIT, J.

Civil Appeal No.5749 OF 2012

1. This appeal by special leave challenges the Judgment and Order dated 11.11.2010 passed by the High Court(The High Court of Judicature at Calcuttta) dismissing Income Tax Appeal No.196 of 2000 and thereby affirming the view taken by the Tribunal(Income Tax Appellate Tribunal, Calcutta) in I.T.A. Nos. 110/Cal/1999 and 402/Cal/1999 on 04.01.2000.

2. The facts leading to the filing of the proceedings before the Tribunal were set out in the Order dated 04.01.2000 as under:-

“2. The assesse before us is PAK-INDO-LANKA, JOINT MANAGEMENT COMMITTTEE (known in short as PILCOM) which is actually a Committee formed by the Cricket Control Boards/Associations of three countries viz. Pakistan, India and Sri Lanka, for the purpose of conducting the World Cup Cricket tournament for the year 1996 in these three countries. Actually, International Cricket Council (ICC) is a non-profit making organization having its Headquarters at London, which controls and conducts the game of cricket in the different countries of the world. ICC has got ni