The CESTAT, Ahmedabad in the matter of M/s. Drishty Communication Private Limited v. C.C.E. & S.T.-Rajkot [Service Tax Appeal No. 135 of 2012 dated January 5, 2023] has held that, advertising in newspapers or media agencies, where the role of the assessee was merely that of an intermediary in the sale of space/ time for media agency on commission basis, cannot lead to an inference that assessee had rendered the services as advertising agency.
Source a2ztaxcorp
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