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2013 (8) TMI 582 - CESTAT NEW DELHISponsorship whether liable for service tax or not - whether sponsorship of the IPL matches by appellants falls within the exclusionary clause of Section 65 (105) (zzzn) – department levied service tax in relation to sponsorship of IPL League matches – Held that:- Fundamental premises of the adjudication authority are misconceived and unsustainable - legislature has incorporated no restriction upon the exclusion by enacting that where a sports events has a commercial purpose, the exclusion was inapplicable - sponsorship of a sports event, which had a commercial element (the IPL events) was disentitled to the benefits of immunity to service tax, notwithstanding the clear phraseology of section 105(65)(zzzn). The provision in issue excludes from liability to service tax, service in relation to sponsorship of sports event - the exclusionary clause admits of no ambiguity, grammatical, syntactical or contextual - legislature in its wisdom has considered it appropriate to extend the benefit of immunity to service tax, to the service of sponsorship in relation to sports events – In the absence of ambiguity, the golden rule of construction namely a construction whereby the literal meaning corresponds to the legal meaning, must be adopted – appeal allowed in favour of assessee.
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