Rental of advertisement structure is not advertisement service where the activity is confined to providing the site.

Letting out a unipole structure on rent was held not to constitute advertisement services because the activity was limited to providing the site and did not include designing, visualising, conceptualising, or otherwise undertaking the advertisement itself. The Tribunal followed its earlier view in the same assessee's case that rental receipts for an advertisement site fall outside the scope of advertisement services, and it found authorities concerning broadcasting to be inapplicable. On that reasoning, the rental income was not exigible to service tax under the advertisement services category, and the Revenue's appeal failed.

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Issues: Whether letting out a structure on rent could be taxed as advertisement services.

Analysis: The activity in question was confined to renting out the unipole structure and did not involve designing, visualising, conceptualising, or otherwise undertaking the advertisement itself. The earlier Tribunal view on the same assessee had already held that rental receipts for the advertisement site do not fall within the scope of advertisement services, and the relied-upon authorities concerning broadcasting were held to be inapplicable.

Conclusion: Letting out the structure on rental basis was not exigible to service tax under the category of advertisement services, and the Revenue's appeal failed.

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