Commissioner of Income Tax (International Taxation)-2 v. Lex Sportel Vision Pvt. Ltd.

1. FACTS OF THE CASE

Revenue appealed under section 260A against the Tribunal’s order of 26 December 2023. Its proposed questions challenged the treatment of foreign remittances, live rights and use of a process under section 9(1)(vi). The Court first condoned 656 days of delay in re-filing the appeal.

Source: Paras 1–4, PDF pp.1–2

2. DISCUSSION BY THE COURT

The Court applied its 15 January 2026 decision in CIT v. Sri Lanka Cricket, ITA 4/2026, reported at 2026 SCC OnLine Del 242. It quoted that decision’s distinction between limited live telecast rights and rights to retain and re-telecast recordings for continuing benefit. The detailed series terms appear within that quotation, not as a fresh recital of Lex Sportel’s contract.

Source: Para 5, PDF pp.2–3

3. JUDICIAL DECISION

Following Sri Lanka Cricket, the Court found no substance or merit in Revenue’s appeal and dismissed it. The dismissal followed condonation of the re-filing delay.

Source: Paras 2,6, PDF pp.1,3

4. OUTCOME

Final assessee-favourable dismissal of the royalty challenge by applying the live-feed precedent. The source does not establish that every broadcasting payment, recording right or bundle of rights is outside royalty.

Source: Paras 5–6, PDF pp.2–3

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Analyse rights rather than the label of a broadcast

Revenue’s questions expressly raised a bouquet of rights and process royalty. The Court nevertheless applied the live-feed decision. For any comparison, the relevant contract rights must be identified; this short order does not reproduce Lex Sportel’s agreement and cannot substitute for that factual exercise.

Source: PDF p.1 · PDF p.2 · PDF p.3

Do not import quoted facts into the current transaction

The twelve-month series restriction, absence of later-match rights and discussion of recording are from Sri Lanka Cricket. They explain the precedent followed here but are not independently established as Lex Sportel-specific terms. Likewise, the quoted SLP withdrawal is background to that precedent, not a disposal of this appeal by the Supreme Court.

Source: PDF p.2 · PDF p.3

Keep procedural indulgence distinct from substantive success

Condonation of 656 days in re-filing permitted the Court to address the appeal; Revenue still lost on the royalty issue. The order supplies neither AY 2018-19 nor a current-law clearance. Its value is the expressly applied precedent and the disposition of this identified appeal.

Source: PDF p.1 · PDF p.2 · PDF p.3