IPL sponsorship linked to a sporting event does not attract service tax under Sponsorship Service.

Sponsorship amounts paid under IPL sponsorship agreements were treated as relating to a sporting event rather than a taxable Sponsorship Service under Section 65(105)(zzzn) of the Finance Act, 1994. The analysis noted that the sponsorship was connected with IPL team franchises and the cricket event itself, and followed a prior decision holding that IPL sponsorship for a sporting event does not attract service tax under this category. On that basis, the appellants were held not liable to pay service tax under Sponsorship Service.

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Issues: Whether the amounts paid under the IPL sponsorship agreements were exigible to service tax as Sponsorship Service under Section 65(105)(zzzn) of the Finance Act, 1994.

Analysis: The arrangement related to sponsorship of IPL team franchises and the activity in substance connected with the sporting event of cricket in IPL. A prior decision on the same issue had held that such sponsorship in relation to the IPL cricket event is a sporting event and does not attract service tax under the category of Sponsorship Service. Following that view, the issue was treated as no longer open for reconsideration.

Conclusion: The appellants were not liable to pay service tax under Sponsorship Service.

Ratio Decidendi: Sponsorship linked to an IPL cricket event, being a sporting event, does not fall within the taxable category of Sponsorship Service under Section 65(105)(zzzn) of the Finance Act, 1994.

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