CIT v. Navjot Singh Sidhu (2023)458 ITR 446 (P&H)(HC)

S. 158BC : Block assessment-Bonus money and prize money-Cricket Board-Circular withdrawing guidelines for treatment of tour money received by Cricket player cannot be applied retrospectively.[S. 132, 260A]

Dismissing the appeal of the Revenue the Court held that the bonus money was the prize money given by the Cricket Board and was exempted from tax. The issue with regard to match fee was covered by the Central Board of Direct Taxes Circular No. 1432 dated November 27, 1987 wherein guidelines for the treatment of tour money received by cricket players had been laid down by the Central Board of Direct Taxes. Though it was withdrawn by a circular dated September 22, 1998 such circular could not have been applied retrospectively. Both these issues came up for consideration before the Commissioner (Appeals) during the course of assessment proceedings and had already been adjudicated in favour of the assessee. Similar issue had been considered in the case of the assessee’s wife for the same block period April 1, 1990 to July 20, 2000, and the appeal of the Department was dismissed. This issue had already been decided in favour of the assessee by the Commissioner (Appeals) and the issue had attained finality. No question of law arose.(BP 1-4-1990 to 20-7-2000)