2023 (9) TMI 1417

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....ax Appellate Tribunal ["CESTAT"] dated 03 August 2018. As would be evident from the recitals appearing in that order, insofar as the issue of Central Value Added Tax ["CENVAT"] Credit was concerned, the same came to be lent a quietus at the stage of appeal itself. The only issue which thereafter appears to have survived for the consideration of CESTAT was with respect to the service tax liability in respect of advertising services. 3. The CESTAT in paragraph 6 of its order records that the appellant in terms of its contract with the Government agency was also obliged to undertake advertising in respect of the toilet blocks, bus queue shelters and other utility services. For the purposes of fulfilment of that contractual obligation, the a....

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....nnected with the making preparation display or exhibition of advertising and that of the advertisement consultant. These definitions make it clear that scope of service which is included in the tax net extends not only to the person involved in making or preparing of advertisements but also includes the service by the person involved in display or exhibition of the advertisement. 9. From the admitted agreement of the appellant it is clear that the appellant had contracted with the M/s. Prime Site and M/s. Graphics Ads for the making or preparation of the advertisements which were to be displayed by the appellant at the site to be constructed by him under an agreement in his favour by MCD. Thus, irrespective M/s. Prime Site and M/s.....