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    <title>2026 (7) TMI 186 - ITAT MUMBAI</title>
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    <description>Protective addition of World Cup receipts and surplus was unjustified where the revenue allocation between cricket boards showed the receipts and expenses were shared by venue, and the assessee had already accounted for the India-linked income. The text states that PILCOM was only a coordinating and managing committee, not an independent taxable association of persons, so income attributed to it was either already dealt with in the proper hands or was not received or receivable by the assessee, especially for matches played outside India. The protective additions were deleted and the assessee&#039;s treatment was upheld.</description>
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      <description>Protective addition of World Cup receipts and surplus was unjustified where the revenue allocation between cricket boards showed the receipts and expenses were shared by venue, and the assessee had already accounted for the India-linked income. The text states that PILCOM was only a coordinating and managing committee, not an independent taxable association of persons, so income attributed to it was either already dealt with in the proper hands or was not received or receivable by the assessee, especially for matches played outside India. The protective additions were deleted and the assessee&#039;s treatment was upheld.</description>
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