Player fee for IPL participation was not taxable as promotional service under Business Auxiliary Services; mixed arrangement could not sustain demand.

Amounts paid to a cricket player as IPL player fee were held not to be consideration for promotional activity under Business Auxiliary Services. The Tribunal found that the contract and surrounding facts showed payment was for playing cricket, with the fee varying by availability and participation, and that mere display of brand names on clothing did not convert the arrangement into taxable promotion. It further applied the principle that, where a composite arrangement cannot be realistically segregated into taxable and non-taxable elements, the demand cannot be sustained on an assumed composite value.

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Issues: Whether the amount received by a cricket player as player fee for participating in IPL matches could be taxed as consideration for promotional activities under Business Auxiliary Services.

Analysis: The contract and the surrounding facts showed that the appellant was paid only for playing cricket, with the payment varying according to availability and participation. The Tribunal followed its earlier decisions on similar IPL player contracts and held that mere display of brand names on clothing did not convert the player fee into taxable promotional service. It also applied the principle that, where a composite or mixed arrangement is not supported by a workable machinery to segregate taxable from non-taxable elements, the demand cannot be sustained on the assumed composite value.

Conclusion: The player fee was not taxable as Business Auxiliary Services, and the demand could not be sustained.

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