No Service Tax on IPO Brokerage: Activities Not Covered by Section 65(19) for Business Auxiliary Services.

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....Demand of service tax - brokerage received on IPO related service - Business Auxiliary Services - appellant’s activity is neither covered u/s 65(19)(i) as they are not promoting or marketing or selling any goods nor u/s 65(19)(i) as it is nor rendered in relation to promotion or marketing of service - IPO is only an offer to the prospective buyers - appellant not covered u/s 65(19)- no service tax....