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2018 (10) TMI 1419 - CESTAT CHENNAIClassification of services - Selling of Space or Time for advertisement, other than print media - agreeing to provide space in backside of the bill for commercial advertisement - appellants have profited at ₹ 0.10 per bill - whether the activity is liable to service tax under the head Selling of Space or Time for advertisement, other than print media? Held that:- The appellant BSNL have a very large number of subscribers to whom all the periodical telephone bills are sent. No doubt, BSNL have opted for lower tender of ₹ 0.58 per A-4 image whereby they have saved some of their printing cost. Quite obviously, the printer puts in the advertisements for commercial benefit. This being the case, the saving of Re.0.10 p per bill is nothing but a consideration or indirect income for allowing 1/5th of the telephone bill space to the printer to put in advertisements - The differential amount saved would very much then become the value of taxable service under the category of ‘sale of space for advertisement service’ in terms of section 65 (105) (zzzm) of the Act. Appellants are liable to pay service tax on the sale of space - appeal dismissed - decided against appellant.
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