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Classification of service - sale of space and time for advertisement service or not - The Appellate Tribunal carefully examined the agreements between the parties and the nature of the services provided. It found that the sponsors were granted rights only to display their names, without any provision for displaying advertisements or products. Considering the definition of sponsorship and relevant legal provisions, the Tribunal concluded that the agreements resembled sponsorship services, which were exempt from taxation for sports events during the relevant period. As a result, the Tribunal set aside the demand raised by the department, allowing the appeal with consequential relief.