TMI Blog2015 (11) TMI 560X X X X Extracts X X X X X X X X Extracts X X X X ..... tisement and includes an advertising consultant; Prima facie, the appellant was not engaged in providing any service connected with making, preparation, display or exhibition of advertisement and it was not an advertisement consultant either. Indeed, the service seems to be more appropriately covered under the scope of Sale of Space or Time for Advertisement Service - prima facie find that the app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e period 2006-07 to 2008-09 was confirmed under Advertising Agency Service. The appellant has contended that it took various hoarding sites on lease and then gave it to various advertisers/advertising agency to display their advertisements for which it received consideration. It paid service tax on such consideration received from the advertisers directly. However, the consideration received for d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sale of Space or Time for Advertisement Service, which is defined as under:- Section 65 (105) (zzzm) to any person , by any other person, in relation to sale of space of time for advertisement, in any manner; but does not include sale of space for advertisement in print media and sale of time slots by a broadcasting agency or organisation. Indeed we find that CBEC vide its instruction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... c media (Doordarshan, private TV channels, AIR etc.) will not be includible in the value of taxable service for the purpose of levy of service tax.The commission received by the advertising agency would, however, be includible in the value of taxable service. 3. In the light of the foregoing, we prima facie find that the appellant is not covered under the scope of advertising agency service an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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