2021 (10) TMI 97

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....ad with Section 65B (44) read with Section 66A & 66B read with Rule 6 of Place of Provisions of Service Rules. The disputes in the appeals are as follows:- Appeal No. Period Demand Show cause notice date Order-in-appeal No. & date ST/A No. 70278/ 2020 April, 2012 to March, 2016 66,58,181/- 16.01.2018 NOI-EXCUS-001-APP-81-20-21 dt.18.05.2020 ST/A No. 70573/ 2020 April, 2016 to June, 2017 51,46,500/- 27.03.2019 NOI-EXCUS-001-APP-543-20-21 dt.28.08.2020 2. Brief facts of the case are that the appellants had acquired 'Media / Broadcasting rights' of various sporting events from M/s Taj TV Ltd., Mauritius, for broadcasting cricket matches between Bangladesh and Zimbabwe (to be played outside India), in Bangladesh....

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.... sports events for the purpose of its commercial exploitation, and the Adjudicating Authority have correctly confirmed the demand with interest and penalty imposed was also upheld. 4. Being aggrieved, the appellant have filed appeals before this Tribunal. 5. Learned Counsel for the appellant(s) contended that no services were provided or consumed within the taxable territory of India. The media rights were procured for broadcasting of the sports event, held outside the taxable territory of India. In this regard the appellant referred to Section 66B of the Finance Act, 1994 and contended that in view of it the service tax would be chargeable only in respect of services provided or agreed to be provided, within the taxable territory. 5.1 F....

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....e services had ever been consumed within the taxable territory of India. Since no services had been effectively consumed within India, imposition of service tax on the value involved is outside the scope of the Finance Act, 1994 and will merely result in hardship and miscarriage of the intention of law. 6. Learned Authorised Representative appearing for the Revenue relies on the impugned order. 7. In respect to the above contention of the appellant we find that section 66B of the Finance Act, 1994 read as under: "There shall be levied a tax (hereinafter referred to as the service tax) at the rate of fourteen per cent. on the value of all services, other than those services specified in the negative list, provided or agreed to be provide....