TMI Blog2014 (2) TMI 758X X X X Extracts X X X X X X X X Extracts X X X X ..... . However, the appeal memorandum seeks to classify the said services under BAS prior to 01/05/2006. This contention of the Revenue is contradictory. If the service is classifiable under “sale of advertising space and time” with effect from 01/05/2006 which is a totally different service and which has not been carved out of BAS, the Revenue cannot contend that the same should be classified under BA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cilitates sale and purchase of goods over internet and they were charging a commission from sellers for successful e-commerce transactions. In addition, they were also charging a listing fee towards banner advertising on the web site wherein the advertisements were flashed on the web site without any creative work involved. The department was of the view that the activity undertaken by the app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... advertising space and time service which came under the tax net with effect from 01/07/2006. Accordingly, he dropped the demand on the consideration received under the category of listing fees. Aggrieved of the same, the Revenue is before us. 3. In the appeal memorandum filed by the Revenue it is urged that the listing fees charged by the appellant would come under the category of BAS for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urged by the Revenue in their appeal memorandum and reiterated by the ld. AR. As per the appeal memorandum, service is classifiable under sale of advertising space and time . However, the appeal memorandum seeks to classify the said services under BAS prior to 01/05/2006. This contention of the Revenue is contradictory. If the service is classifiable under sale of advertising space and time wit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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