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2025 (1) TMI 432

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....of the national and international matches / series held by such national associations within India and abroad, including sponsorship to rights for the national teams controlled and played under the banner of such national associations. 1.1. During the course of audit of accounts of the Appellant and scrutiny of their Profit and Loss Account, S.T-3 Returns, bills and receipt particulars for the years 2010-11 and 2011-12, it was gathered that the Appellant had been showing income under the head "income from sponsorship from sports associations" amounting to Rs.89,74,440/- for the period 2010-11 and Rs.91,09,526/- for the period 2011-12. The audit took the view that the said income received by the Appellant is liable to Service Tax. According....

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.... the service rendered by the Appellant, acting as a marketing agent, liable to Service Tax under the category of 'business auxiliary service'. Therefore, it is contended that the ld. adjudicating authority has traversed beyond the scope of the Show Cause Notice and confirmed a demand which was not there in the Show Cause Notice. Accordingly, the Appellant contends that the demand confirmed in the Order-in-Original and upheld vide the impugned order passed by the Ld. Commissioner (Appeals) is not sustainable. 3.1. The Appellant further submits that the said income was received from the sports associations and as per Section 2(1)(d)(vii) of the Service Tax Rules, 1994, Service Tax in respect of sponsorship amount received by the Appellant is....