ITAT Rules 10% Recorded, 90% Live Revenue Split Fair for Sports Broadcast Licensing Income

The Income Tax Appellate Tribunal (ITAT) has ruled on a fair revenue sharing model for the income derived from the licensing of sports broadcasting rights. In a case involving a sports broadcaster, the tribunal held that a revenue split of 10% for recorded content and 90% for live broadcast content is a reasonable and fair allocation for tax purposes. This decision addresses the issue of how to attribute the income generated from a broadcasting license that covers both the live transmission of a sporting event and the rights to use recorded footage later. The ITAT's ruling provides a clear benchmark for the industry and the tax department on how to segregate and value the different components of a composite broadcasting rights agreement. This helps in determining the correct tax liability and avoids disputes over the allocation of revenue between different types of content.