TMI Blog2017 (3) TMI 866X X X X Extracts X X X X X X X X Extracts X X X X ..... st. Commr (AR), for respondent Per: M.V. Ravindran This appeal is directed against order-in-appeal No. US/419/EGD/2012 dated 28.06.2012. 2. The relevant facts that arise for consideration are appellant are manufacturer of machinery used for fertilizer industry; placed an advertisement in "Fertilizer Focus", a magazine published from U.K.; Revenue authorities were of the view that the amount pai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he category of "sale of space or time for advertisement". It is undisputed that that the magazine 'Fertilizer Focus' which is published in U.K. is only in respect of the items/machinery connected with the fertilizer industry. We find from the records that the payments were made during 2006-07 and 2007-08. On reading the entire definition of "sale of space or time for advertisement" as defined in S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pages, and print catalogues meant for commercial purpose. This has been the claim of the appellant that the magazine 'Fertilizer Focus' published in UK was specifically for the use of the information of the fertilizer industry and the said magazine also included various articles of importance to the fertilizer industry world over. We find that the arguments put forth by learned C.A. in this case ..... X X X X Extracts X X X X X X X X Extracts X X X X
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