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TMI Blog2016 (12) TMI 603X X X X Extracts X X X X X X X X Extracts X X X X ..... Chennai. In the event, the demand of ₹ 9,84,842/- involving service tax on the amounts billed by the appellants, not to the final clients, but only to the advertising agency is required to be set aside, which we hereby do. Demand of ₹ 2,63,977/- - for the period 1997-98 to 2000-01 - incorrect calculation of the tax liability worked out from gross receipts as per Income Tax return a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... volved in this appeal. An amount of ₹ 9,84,842/-has been demanded from the appellants for the period 1997-98 to 2000-01 on the Department's viewpoint that they constitute taxable services rendered to an advertising agency by the appellants which would come within the ambit of advertising agency service. Further, a demand of ₹ 2,63,977/- has also been confirmed for the period 1997-9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r own hoardings to advertising agencies, which in turn bills the ultimate clients, then the advertising agencies become service providers, who are responsible to pay service tax on the gross amount including the money paid to the hoarding company; however the hoarding company becomes liable to pay service tax when they are directly billing the clients and not the advertising agencies. Secondly, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ugned order. However he concedes that the clarifications referred to above have indeed been issued by the Department. 4.1 . Heard both sides. In respect of the first issue, involving demand of ₹ 9,84,842/- we find considerable merit in the submissions of the learned counsel. The Department has clarified the matter to the Advertising Associations in Bangalore and Chennai. The case laws rel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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