Respondent liable for service tax on public relations services for Government under broad scope defined by Act.

The tribunal held that the respondent's activities constituted management of public relations services for the Government, as per the broad scope defined under the Act. Despite being registered under advertising agency services, the respondent failed to declare the income received from the Government for service tax. The tribunal confirmed the liability for service tax, interest, and penalties, overturning the dropping of the tax demand by the Commissioner. The revenue's appeal was allowed, and the respondent's objections were dismissed.

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Issues:
1. Whether the service rendered falls under "Public Relation Service" for levy of service taxRs.
2. Whether the activities undertaken by the respondent constitute "management" of public relationsRs.
3. Whether the respondent is liable to pay service tax, interest, and penalty for the services provided to the GovernmentRs.

Analysis:
1. The appeal was against the dropping of a service tax demand of Rs. 3,06,78,267 by the Commissioner concerning an agreement for Integrated Mobile Publicity in Assembly Constituencies. The respondent provided services through Publicity Mobile Vans, screening movies and advertisements. The department viewed it as falling under "Public Relation Service" and issued a show cause notice. The adjudicating authority dropped the proceedings, stating the activities were not public relations management. The respondent argued that they merely executed instructions and were not involved in management. The tribunal disagreed, citing the broad scope of public relations services under the Act.

2. The tribunal analyzed the definition of "Public Relations" under section 65(86c) of the Act, emphasizing that management includes guiding, directing, and executing work. The tribunal found that the respondent was entrusted with implementing the public relations program of the Government, indicating a management role. The respondent's argument that they only provided infrastructure was rejected, as managing public relations involves planning and organizing activities, which the respondent did on a state-wise basis. Therefore, the tribunal concluded that the respondent's activities constituted management of the public relations campaign.

3. The tribunal held that the respondent's activities fell within the definition of public relations services based on the contract terms with the Government. Despite being registered under advertising agency services, the respondent failed to include the amount received from the Government for service tax. The tribunal confirmed the liability for service tax, interest under section 75 of the Act, and imposed penalties as proposed in the show cause notice. Consequently, the appeal by the revenue was allowed, and the respondent's objections were disposed of.

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