TaxTMI 
TaxTMI 
2025 (6) TMI 1093
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....arious companies towards sponsorship in respect of Indian Premier League (IPL) T20 Tournament during the period 2010-11 and not paid service tax under the category of 'Sponsorship Services', proceedings were initiated and adjudicating authority as per the impugned order confirmed the demand and also imposed penalty. Aggrieved by the said order, the present appeal is filed. 2. When the appeal came up for hearing, the learned counsel for the appellant submitted that the entire demand except reflected in Sl. No.10 (in Annexure-I to the show-cause notice) pertains to M/s. Royal Challengers Sports Private Limited dated 31.03.2011 is unsustainable, since the service tax on sponsorship of sports was brought into taxable category only with effec....
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....d the invoice for the last activity was issued vide invoice dated 24.07.2010. The learned counsel also drew our attention to the agreement entered by the appellant with different clients and also submitted that as per Section 65(105)(zzzn) of the Finance Act, 1994, prior to 01.07.2010 'Sponsorship Service' is defined as which excludes 'the services in relation to sponsorship of sports events' from the purview of taxability of "Sponsorship Service". Thus, the statute merely envisages a nexus between the sports event and the sponsorship services to get excluded from the scope of the taxability of sponsorship services. In the light of the said legal position, the Appellant did not discharge service tax on the sponsorship amounts paid to the Fr....
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....ance Act, 1994 "Sponsorship Services", to any body corporate or firm, by any person receiving sponsorship, in relation to such sponsorship, in any manner, but does not include services in relation to sponsorship of sports events; Post 01.07.2010 Under Section 65(99a) of the Finance Act, 1994 "Sponsorship" includes naming an event after the sponsor, displaying the sponsor's company logo or trading name, giving the sponsor exclusive or priority booking rights, sponsoring prizes or trophies for competition; but does not include any financial or other support in the form of donations or gifts, given by the donors subject to the condition that the service provider is under no obligation to provide anything in ....
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.... which reads as: "Provided further that notwithstanding the time of receipt of payment towards value of services, no service tax shall be payable for the part or whole of value of services, which is attributable to service provided during the period when such service was not taxable". Hence, the demands made under Sl.No.3 and 8 of Annexure - 1 of show-cause notice with respect to (i) Bill No.KRSTL/2010-11/USL4 dated 12.07.2010 issued by IPL Team, Knight Raiders to the appellant and (ii) Bill No.13/DCSVL/2010 dated 24.07.2010 issued by IPL Team, Decan Chargers, are set aside since the last match was concluded on 25.04.2010 i.e., services were rendered prior to 01.07.2010. 4.2 As regarding the demand confirmed for the services ....