9911796707
TMI Blog2014 (1) TMI 1143X X X X Extracts X X X X X X X X Extracts X X X X ..... which the Revenue has developed the argument that the entire services of advertisement were being provided by the appellant and the consideration was being routed through GRP M. As per the appellant M/s. GRP M is charging full amount from their client and is only passing a part amount to the appellant as a consideration for their creative inputs in which case the interpretation of the agreement by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ive Media. As per the said agreement, the appellants clients were referred to other advertisement agency but appellant was to put some creative contribution to the advertisement being made by the other agency. On the said account, the appellant was being paid some sort of commission by other advertising agency. 2. Revenue, by treating the said commission as the consideration for providing advert ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he appellant to other advertisement agency would not fall under the category of such definition. He also draws our attention to the Board s Circular indicating that where the entire Service Tax stand paid by the main contractor, the sub-contractor need not pay any Service Tax. The said circular was withdrawn with effect from 16-8-2007. Inasmuch as the demand is for the period prior to that, the sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed from GRP M. 5. After considering and appreciating the submissions made by both sides, we find that there is no dispute about the execution of the agreement as also providing of advertisement service to GRP M to the ultimate client. It is only reading of the agreement by which the Revenue has developed the argument that the entire services of advertisement were being provided by the appellant ..... X X X X Extracts X X X X X X X X Extracts X X X X
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