The assessee is a cricket association registered under Society registration Act 1860 and also earlier granted registration u/s 12A of the Act .For the relevant year the assessee received amount by way of subsidy , reimbursement from BCCI , share of TV subsidy and IPL subvention from BCCI  , service charges for IPL, income from members  income from international Match , interest from Bank, other income  etc  .  The assessee claimed exemption u/s 2(15) of the Act on the ground that the object of assessee would fall under the limb advancement of any other object of general public utility and included in the definition of charitable purpose . AO disallowed the claim in view of the amendment to S. 2(15) of the Act, the activities of the assessee were not charitable purpose disallowed the claim u/s 11(2) of the Act. CIT(A) also affirmed the view of the AO. On appeal the Tribunal held that though the assessee is activity contributing towards the promotion and popularity of cricket, its activities are also concentrated for generation of revenue by exploiting the popularity of the game and towards monopolization and dominant control over cricket to the exclusion of others. The commercial exploitation of the popularity of the game and the property/infrastructure held by the assessee is not incidental to the main object but is one of the primary motives of the assessee.  Tribunal held that after verification of the accounts of the assessee as to ascertain which part of the club income and catering services has generated from members of the assessee association and which part of the income is earned from non -members . It is also to be looked in to whether the income from the club house and other facilities is generated from the members only and the receipt from non members is an exception or the income is generated from members is an exception or income is generated from members and non members is normal course of business . Whether the catering services are limited to the members and their guests only or the same also provided to non -members also on commercial basis . The AO after thoroughly examining the facts will decide if the principle of mutuality applies to club income including catering contact in accordance with  law. Accordingly the matter is restored to the file of the AO.   Tribunal also stated that the observations made in the order  will not have any bearing as such on any adjudication in the cases of the BCCI and that the BCCI will have right and liberty to contest its cases irrespective of the observations given above as our findings rests on the pleadings of the parties before us though, the viewpoint of the BCCI has also been considered after giving due opportunity to the BCCI (ITA No. 427/Chd/2017.( ITA No. 427/CHD /2017, dt. 12.09.2019)(AY. 2010-11)