In a remarkable display of financial acumen, Sachin Tendulkar, the Master Blaster of cricket, successfully argued before tax authorities that he was not just a cricketer but also an "actor" for endorsement deals. This strategic move, dating back to the financial year 2002-03, allowed him to save approximately Rs 58 lakh in income tax. Tendulkar had earned Rs 5.92 crore in foreign income from high-profile endorsements with global brands such as Pepsi, Visa, and ESPN. Rather than categorizing these earnings under his primary profession as a cricketer, he declared them as income from his secondary profession as an actor, invoking Section 80RR of the Income Tax Act, 1961.
Section 80RR provides a deduction of up to 30% on foreign income earned by individuals in creative fields, including authors, playwrights, artists, actors, musicians, and even sportsmen when their work involves performative elements. Tendulkar's claim hinged on the argument that his appearances in television commercials and modeling assignments required acting skills, imagination, and creative expression—qualities that aligned with the definition of an "actor" under the section. He calculated a deduction of Rs 1.77 crore (30% of Rs 5.92 crore), but this was initially rejected by the Assessing Officer (AO), who viewed the endorsements as incidental to his cricketing fame and taxable under "Income from Other Sources" without any special relief.
The dispute escalated to the Income Tax Appellate Tribunal (ITAT), where Tendulkar's legal team presented a robust defense. They emphasized that an individual can pursue multiple professions simultaneously, and the endorsement income stemmed directly from his acting and modeling performances, not his on-field cricket exploits. The ITAT adopted a broad interpretation of "actor," defining it as any work involving skill, imagination, creativity, and aesthetic output. This included TV ads and modeling, ruling that Tendulkar's dual roles as cricketer and performer were valid and separate.
Ultimately, the ITAT ruled in Tendulkar's favor, upholding the full Rs 1.77 crore deduction and setting a precedent for professionals in creative and performative domains. As highlighted by Sujit Bangar, founder of Taxbuddy.com, in his viral X post, this case underscores the importance of precise tax classification and creative legal reasoning. It serves as an inspiring example for freelancers, artists, and endorsers on how nuanced understanding of tax provisions like Section 80RR can yield substantial savings, provided the claims are substantiated with evidence of artistic contribution.