Business exhibition service requires an exhibition to market or showcase services; supplying media-centre space alone is not taxable.

Providing space and ancillary facilities for a media centre during the Commonwealth Games did not amount to business exhibition service because the arrangement was not an exhibition to market, promote, advertise, or showcase products or services. The essential ingredients of business exhibition service under the Finance Act were therefore absent, so no taxable service arose. As a result, the service tax demand, interest, and penalty could not be sustained, and reverse charge liability also did not arise.

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Issues: Whether providing space and ancillary amenities to another department of the Government of India for setting up a media centre during the Commonwealth Games amounted to business exhibition service and attracted service tax, including liability on reverse charge basis.

Analysis: The arrangement was for providing space with incidental facilities for a media centre meant for dissemination and telecasting of sports news, not for organising an exhibition to market, promote, advertise, or showcase products or services. The essential ingredients of business exhibition service under Section 65(105)(zzo) read with Section 65(19a) of the Finance Act were therefore not satisfied. As no taxable service was being rendered in these facts, the demand could not be sustained and reverse charge liability also did not arise.

Conclusion: The service tax demand, interest, and penalty were set aside, and the appellant was held not liable to service tax under business exhibition service or on reverse charge basis.

Final Conclusion: The appeal succeeded and the appellant obtained consequential relief in law.

Ratio Decidendi: Mere provision of space and allied facilities for a media centre does not constitute business exhibition service unless the activity is an exhibition intended to market, promote, advertise, or display products or services.

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