Section 2(15) & 11 of the Income Tax Act, 1961 — Act, 1961 — Trust — Exemption — Since BCCI is being treated as an AOP of State Associations by the tax authorities and the payments made to its members i.e state Associations has been treated as distribution of profits, the said payments having been already taxed at hands of BCCI cannot be taxed again in hands of the assessee. Commercial exploitation of the popularity of Cricket and its infrastructure by the assessee is not incidental but is inter alia, one of the main activities of assessee, hence, despite having the objects of promotion of sports, the activity of the assessee being also directed for generation of profits on commercial lines will exclude it from scope of Charitable activity — Punjab Cricket Association vs. Assistant Commissioner of income tax [2019] 202 TTJ (Chandigarh) 137