Assessee State Cricket Association was affiliated to parent body, BCCI . It used to receive funds from BCCI to carry out activities including payment of tax dues .  Under Direct Tax Dispute Resolution Scheme, 2016, a declaration was made by assessee, income tax department sought to issue certificate on condition that assessee should deposit tax on or before date specified . However, in case of BCCI, Supreme Court had already passed an order injuncting BCCI from paying money to State Cricket Associations . Since assessee was incapacitated from reasons beyond its control and power, writ of mandamus were to be issued that BCCI should pay tax and interest on behalf of assessee within 180 days . (AY. 2006 -07 to 2012-13 )