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Custom, Excise & Service Tax Tribunal

Secunderabad - G S T vs Macro Media Digital Imaging Pvt Ltd on 14 September, 2022

Author: Dilip Gupta

Bench: Dilip Gupta

 CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL
                    HYDERABAD
                           REGIONAL BENCH

             SERVICE TAX APPEAL NO. 23542 OF 2014

(Arising out of Order-in-Original No. HYD-EXCUS-003-COM-20/14-15      dated
18.07.2014 passed by the Commissioner of Central Excise, Hyderabad)


Commissioner of Central Excise,                           ...Appellant
Hyderabad-III Commissionerate, Hyderabad


                                     versus


Macro Media Digital Imaging Pvt. Ltd.                     ...Respondent
147/D, Secto-I, Line-1, Phase-II,
Cherlapally IDA, Hyderabad- 500051
(Telangana State)


Appearance

Mr. V.R. Pavan Kumar, Authorized Representative of the Department
Mr. S. Thirumalai, Advocate for the Respondent

CORAM:

HON'BLE MR. JUSTICE DILIP GUPTA, PRESIDENT
HON'BLE MR. P.V. SUBBA RAO, MEMBER (TECHNICAL)


                                              Date of Hearing: 04.05.2022
                                              Date of Decision: 14.09.2022


                  FINAL ORDER NO. A/30086/2022


JUSTICE DILIP GUPTA:



      The Department has filed this appeal to assail the order dated

18.07.2014 passed by the Commissioner of Customs, Central Excise

and Service Tax, Hyderabad1, by which the proceedings initiated by

show cause notices dated 22.10.2012 and 12.05.2014 have been

dropped.

2.    The first show cause notice dated 22.10.2012 was issued for the

period April 2007 to March 2012 calling upon M/s. Macro Media Digital



1.    the Commissioner
                                          2
                                                                      ST/23542/2014


Imaging Private Limited 2 to pay service tax on „advertising agency‟

services with interest and penalty. The second show cause notice

dated 12.05.2014 was issued for the subsequent period from April

2012 to March 2013.

3.     According to the respondent, it is engaged in the business of

„wide format printing‟. It has no role in conceptualization or in making

or creation of design for advertisement to be printed for customers.

The customers provide the „ready to print‟ advertisement content and

the respondent undertakes the printing of such content on PVC

material procured by the respondent from the open market. The

respondent has no authority from the customers for making any

changes since the scope of the activity is limited to printing. Thus,

according to the respondent, it has no role in the „making of the

advertisement‟.

4.     However, a show cause notice dated 22.10.2012 was issued to

the respondent for recovery of service tax for the period April 2007 to

March 2012. The show cause notice was issued to show cause as to

why-

        a.   An amount of Rs. 21,66,58,906/- (including cesses)
             should not be demanded from them towards service
             tax payable on account of „Advertisement Services‟
             provided by them under section 73(1) of the Finance
             Act, 1994 read with the proviso thereto:

        b.   Interest at the applicable rates should not be paid by
             them under the provisions of section 75 of the
             Finance Act, 1994 on the amount demanded at (i)
             supra.

        c.   Penalty should not be imposed on them under
             section   76   of   the   Finance   Act,   1994   for   the



2.     the respondent
                                                  3
                                                                                   ST/23542/2014


              contravention of statutory provisions, as detailed
              supra during the period prior to 10.05.2008.

         d.   Penalty should not be imposed on them under
              section     77        of   the   Finance   Act,   1994      for     the
              contravention of statutory provisions, as detailed
              supra.

         e.   Penalty should not be imposed on them under
              section 78 of the Finance Act, 1994 for mis-
              statement, suppression of facts and contravention of
              provisions of chapter V of the Finance Act or the
              rules made there under, with intent to evade
              payment of service tax as detained in the notice.

5.    The relevant portion of the show cause notice is reproduced

below:

              "5.       The activity of Macromedia is to provide services
              related     advertising/marketing          campaigns        of    their
              customers             though      converting      digital        format
              communication media into quality wide format printing.
              Though Macromedia claims that they are mainly engaged
              in wide format printing on flex banners, they are not
              disputing the fact that the printing done only for the
              purpose of advertisement. In clear parlance, the assessee,
              admittedly       is    engaged     in   production   and     sale    of
              advertising materials based on orders received from their
              customers. xxxxxxxx."



6.   This show cause notice was followed by another show cause

notice dated 12.05.2014 for the subsequent period from April 2012 to

March 2013.

7.   The appellant filed a detailed reply to the aforesaid show cause

notice. The factual description of the activities undertaken by the

respondent have been stated to be as follows:

              9.        It is submitted that the noticee is in the
              business of 'wide/large format printing wherein the
              notice undertakes printing activity for the banners,
                                          4
                                                                      ST/23542/2014


             billboard, etc. as per the design content provided by
             the customers on PVC/flex materials.

             10. In this regard, it is submitted that the noticee's
             activity     does    not    involve      any    designing,
             conceptualization of the advertising content but
             limited to the printing as per the designs supplied
             by the customers. This factual position is not disputed in
             the SCN under reply as can be seen from the averments in
             para 7. It is pertinent to note here that the noticee is not
             even involved in the modification of such designs and
             merely checks the printability aspect of the design so
             supplied before undertaking the printing activity as per the
             customer requirements.
             xxxxxxxxxx
             11.    It is also submitted that the noticee is also
             not authorized by the customers for making any
             changes in the designs supplied neither having any
             specialization in creation or conceptualization of
             such design so as to get covered under the term
             'making    of   advertisement.     The    Purchase   orders
             received from the customers clearly evidenced that the
             activity carried out by the noticee is mere printing of the
             materials based on the design and specification provided
             by the customers and by no stretch of imagination be
             treated as 'making of advertisement'. xxxxxxxxxxxx.

             xxxxxxxxxxxx"


8.    A similar reply was filed by the respondent to the second show

cause notice dated 12.05.2014.

9.    The Commissioner, by order dated 18.07.2014, dropped the

proceedings initiated by the two show cause notices.

10.   Shri V.R. Pavan Kumar, the learned authorised representative

appearing for the department, made the following submissions:

       (i)   In respect to the bills raised by the respondent, the
             consumers are deducting TDS which clearly indicates
             that the activity undertaken by the appellant is a
             service;
       (ii) This apart, the respondent have not discharged VAT
             on merits, but only under a composition scheme
                                          5
                                                                  ST/23542/2014


              which indicates that service is involved in the
              transfer of goods;
       (iii) From the definition of „advertising agency‟ under
              section 65 (3) of the Finance Act, any person
              engaged in providing any service connected with the
              making, preparation or display of advertisement
              would be providing „advertising agency‟ services;
       (iv) The Commissioner committed an error in placing
              reliance upon the letter of CBEC dated 16.08.1999
              granting exemption to persons engaged in printing
              and publishing of telephone directories, yellow pages
              or business directories;
       (v) The Commissioner also committed an illegality in
              referring to the Circular dated 23.08.2007 which
              clarified that mere canvassing advertisements for
              publishing on commission basis is not classifiable
              under advertising service; and
       (vi) To support these contentions, the learned authorised
              representative placed reliance upon the decision of
              the Kerala High Court in Commissioner of Central
              Excise & Customs vs. Zodiac Advertisers 3 and
              the decision of the Supreme Court in the appeal filed
              by Zodiac Advertisers, which decision is reported in
              Zodiac Advertisers vs. Commissioner of C. Ex. &
              Cus., Cochin4.


11.   Shri     S.   Thirumalai,    learned     counsel   appearing     for   the

respondent, however, supported the impugned order and broadly

made submissions under the following three heads:


             'Advertising Agency' services does not include mere
                      printing of advertisement material


       (i)     Activity of printing „ready to print‟ advertisement
               context on PVC flex material and sale of such printed
               material amounts to sale of goods but not a service
               and thereby no service tax is payable on the said
               activity under „advertising agency‟ service;

3.    2009 (13) S.T.R. 593 (Ker.)
4.    2009 (14) S.T.R. 449 (S.C.)
                                      6
                                                                               ST/23542/2014


(ii) A person shall be considered to be an „advertising
     agency‟, if he is engaged in providing any service
     connected with making, preparation, display or
     exhibition of advertisement. As the activity of the
     respondent         is    printing        of     „ready       to        print‟
     advertisement content on PVC material and sale of
     the same to customers, the plea of the department
     that the same would come under the ambit of
     „advertising agency‟ is not correct;
(iii) In view of the clarification given by the Calcutta
     Commissionerate in the letter dated 16.08.1999, it is
     clear that mere printing of „ready-made‟ or „ready to
     print‟ advertisement cannot be considered as service
     leviable to service tax under „advertising agency‟
     services. In order to levy tax on any activity under
     „advertising agency‟ services, the activity should be
     related      to        making    or       preparation             of      an
     advertisement,          such    as       designing,       visualizing,
     conceptualizing etc. which is absent in the present
     case;
(iv) An „advertisement agency‟ basically prepares the
     contents     of    the    advertisement           material        and      is
     strategically involved in the manner in which the
     content     of    such    advertisement           is   displayed          or
     exhibited to the targeted public. The legislative
     intent is not to tax every activity connected with
     advertisement;
(v) The CBEC, by letter dated 23.08.2007, had clarified
     that persons/agencies who canvas advertisement for
     publishing        on    commission            basis    and     do        not
     undertake          any      activity          involving           making,
     preparation, display or exhibition of advertisement
     do not come under the ambit of „advertising agency‟
     services;


  Printing activity amounts to 'manufacture' and so no
                        service tax is payable

(vi) The activity of printing of advertisement content on
     PVC material resulting into printed PVC flex or PVC
     board     are     considered        as    products        of      printing
                                            7
                                                                              ST/23542/2014


            industry.      Such    printing       activity        results    into
            „manufacture‟ as defined under section 2(f) of the
            Central     Excise    Act,    1944.    These          products   are
            classifiable under the Tariff 4911 10 10 of the
            Central Excise Tariff and are exempted from levy of
            central excise duty;


  No service tax payable from 01.07.2012 onwards as printing
                            activity is not a 'service'


       (vii) The order passed by the adjudicating authority also
            sets aside the demand of service tax under the
            subsequent show cause notice for the period from
            01.07.2012 to 31.03.2013. Though the appellant has
            preferred this appeal against the entire order, but no
            grounds have been stated in the appeal memo
            challenging the findings of the adjudicating authority
            that no service tax is payable for this period; and

      (viii) The show cause notice for the subsequent period
            April 2012 to March 2013 fails to specify under what
            charges the respondent was being subjected to
            service tax levy under the Negative list-based
            taxation effective from 01.07.2012.

                                  DISCUSSION

12.   The   submissions          advanced         by        the    learned      authorized

representative appearing for department and the learned counsel

appearing for the respondent have been considered.

13.   The issue that arises for consideration is whether the activity of

"wide format printing" and „supply of advertising material to clients‟

based on the designs provided by the clients would amount to

rendering any service. According to the respondent it had no role in

conceptualization     or   in    the     making        or    creation of design for

advertisement to be printed for customers, for the appellant merely

carried out the activity of wide format printing and supply of
                                        8
                                                                          ST/23542/2014


advertisement material to the clients. The customers provided the

„ready to print‟ advertisement content and the respondent undertook

the printing of such content on PVC material procured by the

respondent from the open market. The respondent also contends that

it has no authority from the customers to make any changes in the

advertisement content provided by customers and the scope of the

activity is limited to printing the contents provided by the customers

on the PVC material. Thus, according to the respondent, it has no role

in the „making of advertisement‟. According to the Department, the

work undertaken by the respondent would amount to a service under

the category of „advertising agency‟ service as defined in section 65

(3) of the Finance Act and made taxable under section 65 (105)(e) of

the Finance Act.

14.   To appreciate the contentions, it would be appropriate to

reproduce the definition of „advertising agency‟. It is defined under

section 65(3) of the Finance Act as follows:-

              "Section   65(3):    „advertising   agency‟    means       any
              person engaged in providing any service connected with
              the   making,   preparation,   display   or   exhibition    of
              advertisement and includes an advertising consultant."


15.   It is made taxable under section 65 (105)(e) of the Finance Act

and it is reproduced below:

              "Section 65 (105)(e): „taxable service‟ means any
              service provided or to be provided to any person, by an
              advertising agency in relation to advertisement in any
              manner."



16.   The Commissioner, after examining the nature of the work

undertaken by the respondent, noted that what was required to be

decided was whether mere printing activity can be considered as
                                            9
                                                                            ST/23542/2014


„advertising agency‟ services only because the printed matter is

advertisement material. After referring to various decisions of the

Tribunal and the Circulars issued by the Board, the Commissioner held

that the activity of printing of flex banners by the respondent as per

the requirement of the customers and selling the same to the

customers would not be covered under the scope of the „advertising

agency‟ services for the period prior to 01.07.2012 and even for the

period post 01.07.2012, the activity undertaken by the respondent,

being merely transfer of goods by sale which is subject to Sales

Tax/VAT on the full value, is excluded from the scope of the service

tax under section 65B (44)(a)(i) of the Finance Act. The relevant

portions of the order passed by the Commissioner are reproduced

below:

           20.    I have examined the records of the case and the
           submissions made by the assessee carefully. The point
           for decision is whether or not the assessee is liable
           for service tax as advertising agency in respect of
           activities undertaken by them. The admitted facts of
           the case are that the assessee are undertaking
           printing work of flex banners, bill boards etc., as per
           the design and content provided by the customers.
           They have printing machines for wide/large format
           printing. It is also an admitted fact that they are not
           involved in any designing, conceptualizing of the
           advertising content and their activities are limited to
           printing     as    per   the    designs       supplied     by   the
           customers. The only point on which service tax liability
           was sought to be confirmed is that they are engaged in
           printing and making advertisement material with the
           name, product name, logo or trade mark etc., of the
           customers.    In    other     words,   they    are   engaged     in
           production and sale of advertising material based on
           orders received from their customers. Since as per the
           definition under Section 65(3) of the Finance Act, 1994,
           "advertising Agency" means any person engaged in
           providing    any    service    connected      with   the   making,
                              10
                                                            ST/23542/2014


preparation, display or exhibition advertisement includes
advertising consultancy and as the assessee are engaged
in production and sale of flex banners, boards containing
the advertisement given by the customers, they are
sought to be included in „Advertising Agency‟. The work
of such agency covers within its ambit any service
connected     with    making,     preparation    display    or
exhibition    of   advertisement.     The    assessees     are
involved in printing and selling flex boards and
banners containing advertisements, as such they
are also sought to be included under the category of
Advertising Agency. Support for this was drawn from
the terms 'any service connected with making, preparation
of advertisement'. The assessees strongly contested their
liability for the service tax stating that they are involved in
printing as per the requirements of their customers and
are no way connected with the creation of contents or
subsequent display of the advertisement materials. They
have expertise in printing and they are not involved in any
conceptualization, designing or consultation in advertising
of any product or service of the customers in any manner.
In simple terms, the point for decision is whether a mere
printing activity can be considered as a work of advertising
agency, only because the printed matter is advertisement
material. The thrust given in the show notice that
any   person       engaged   in   making     advertisement
material should be considered as advertising agency
is misleading.

xxxxxxxxx

24.    Board vide letter F.No. 345/4/97-TRU dated
16.08.1999 while examining the service tax liability
of printing and publishing telephone directories,
yellow pages or business directories, clarified that
their activity is essentially of printing a readymade
advertisements from the advertisers and publishing
the same in the directory. Their activities are similar
to those carried out by newspapers or periodicals.
As such, this activity shall not attract service tax.
However, if these persons also undertake any activity
relating to making or preparation of an advertisement,
such as designing, visualizing, conceptualizing etc., they
will be liable to pay service tax on the charges made
thereon".
                                             11
                                                                                ST/23542/2014



           25.   Further,     vide    circular         No.6/7/2007-ST       dated
           23.08.2007,        the     Board       clarified      that      merely
           canvassing       advertisements              for     publishing      on
           commission         basis    is        not     classifiable       under
           advertising services.

           26.    It is also noticed that the printed material is
           sold by the assessee to their customers and VAT is
           being discharged on the value. The transaction
           between      the    assessee          and      the     customer       is
           essentially on sale of goods. The processes involved in
           preparation of the flex boards and banners resulting in
           printed material containing components of advertisement,
           can more appropriately be considered as production and
           processing of goods for the customers.

           27.    Considering the above legal position, case
           laws and discussion, I find that the activity of
           printing    of   flex     banners,      boards        etc.,    by   the
           assessee as per the requirement of the customers
           and selling the same to the customers cannot be
           covered under the scope of advertising agency for
           the purpose of service tax. For the period after
           01.07.2012, the activity undertaken by the assessee
           being merely transfer of title on goods by sale
           subjected to sales tax/vat on the full value is
           excluded from the scope of service tax as per
           Section 65B(44)(a)(1). As already noted, the only basis
           on which the service tax was sought to be levied on the
           assessee, is that they are engaged in making and
           producing    banners        and       flex     boards,        containing
           advertisements. No other activity has been alleged or
           evidenced. It is also not disputed that there is sale
           transaction of the said products and material. As such I
           find levy of service tax on the assessee based on the
           allegation made in show cause notice is not sustainable."

                                                        (emphasis supplied)



17.   As noticed above „advertising agency‟ has been defined to mean

any person engaged in providing any service connected with the

making, the preparation, display or exhibition of advertisement. It is

not in dispute that in the present case the customers provide the
                                         12
                                                                       ST/23542/2014


„ready to print‟ advertising content to the respondent and the

respondent merely prints the advertisement content on the PVC

material procured by the respondent from the open market. The

respondent has no role at all in the conceptualization or in the making

or creation of design. In fact, the respondent has no authority at all to

even make any changes in the advertisement content provided by the

customers and the respondent merely prints that on the PVC material

procured from the market. This activity would not fall within the scope

of the activity contemplated under section 65(3) of the Finance Act.

18.   This issue was also considered in the Trade Notice dated

16.08.1999    issued     by     the    Calcutta       Commissionerate.        After

examination of the matter, it was decided that where ready made

advertisement provided by the customers is printed and published in

the telephone directory, the activity will not attract service tax and it

is only when persons also undertake any activity relating to making or

preparation of an advertisement that service tax would be levied. The

said Trade noticed dated 16.08.1999 is reproduced below:

                           "Trade Notice - Service Tax

                 Trade Notice No. 99/GL-90/C.E./PRO/CAL-II/99

                              Calcutta Commissionerate


                                                      Dated 16-08-1999

              Communicated by CBEC through 345/4/97-TRU
              dated 16.08.1999


              Attention of the Trade and Field Formations are invited
              to the fact that doubts have been raised as to whether
              persons engaged in the activity of compilation, printing
              and publishing of telephone directories, Yellow pages
              and   business    directories   are   covered   under   the
              definition of „advertising agency‟ and accordingly liable
              to pay service tax.
                                         13
                                                                           ST/23542/2014


             2.    The matter has been examined by the Ministry of
             Finance, Department of Revenue (Tax Research Unit).
             It has been decided that in the case of persons, who
             are printing and publishing telephone directories, Yellow
             pages     or   business    directories,    their   activity    is
             essentially of printing a readymade advertisement from
             the    advertisers   and   publishing     the   same   in     the
             directory. Their activities are similar to those carried
             out by newspapers or periodicals. As such, this activity
             shall not attract service tax. However, if these persons
             also undertake any activity relating to making or
             preparation of an advertisement, such as designing,
             visualizing, conceptualizing etc., then they will be liable
             to pay service tax on the charges made thereon."



19.   It would also be important to refer to the „Frequently Asked

Questions‟ on Service Tax issued by the Chief Commissioner of

Central Excise, Coimbatore Zone (Third Edition dated 19.06.2006). It

provides that mere publishing of prepared advertisement in a paper or

magazine is not the function of an „advertisement agency‟ and hence

would not fall within the scope of „advertising agency‟ service. The

same is reproduced below:

                 "Frequently Asked Questions on Service Tax

             Chief Commissioner of Central Excise, Coimbatore
             Zone - Third Edition dated 19-06-2006

                              17.15. Advertising agency
             Scope:
                  The taxable service provided or to be provided to a
             client by any person in relation to making preparation,
             display or exhibition of advertisement i.e., circular, label,
             wrapper, document, hoarding or any other audio or visual
             representation made by means of light, sound, smoke or
             gas for publicity is covered under the category of
             Advertising agency service.

                  Advertisement agency basically prepares content of
             the advertisement material for publicity as per the
             requirement of the client and/or arranges the space in any
             kind of media.
                                             14
                                                                           ST/23542/2014


                Inclusion:
                    The definition of „advertising agency‟ also covers
                „advertising consultant‟.
                    Market research relating to advertisement forms part
                of the service in relation to the advertisement.

                Exclusion:

                    Mere publishing of prepared advertisement in a
                paper   or    magazine      or     broadcast   of    prepared
                advertisement on electronic media by TV or Radio
                channel are not the functions of an advertisement
                agency. Hence such activities do not fall within the
                scope of the Advertisement agency service."



20.    It would also be useful to refer to the Master Circular dated

23.08.2007 clarifying technical issues relating to taxation of services.

In    respect   of   the     issue     as    to     whether     merely     canvassing

advertisement for publishing on a commission basis would attract levy

of service tax, the said Circular mentions that it would not be taxable

under section 65(105) (e) of the Finance Act. The relevant portion of

the Circular is reproduced below:

                     "Circular 96/7/2007-ST dated 23.08.2007

                Master Circular clarifying technical issues relating
                to taxation of services


                           Circular No. 96/7/2007-S.T., dated 23.08.2007

                                                    F.No. 354/28/2007-TRU


                                     Government of India

                     Ministry of Finance (Department of Revenue)

                     Central Board of Excise & Customs, New Delhi


                xxxxxxxxxx

                Referenc                    Issue                     Clarification
                 e Code
                   (1)                       (2)                          (3)
                004.01/       Persons/agencies      canvass         Merely canvassing
                23.08.07      advertisements for publishing,        advertisement for
                              on commission basis. Such             publishing,    on
                              persons/agencies    do     not        commission basis,
                                            15
                                                                            ST/23542/2014


                              provide any other services like      is not classifiable
                              making, preparation, display or      under the taxable
                              exhibition of advertisement.         service      falling
                                                                   under       section
                              Whether merely canvassing            65(105)(e).
                              advertisement for publishing
                              on a commission basis by             Such services are
                              persons/agencies is classifiable     liable to service
                              as Advertising Agency service        tax under business
                              [section 64(105)(e)] or not?         auxiliary  service
                                                                   [section
                                                                   65(105)(zzb)].



21.   It also needs to be noted that the Commissioner has also, after

noticing   that     the    respondent       is     not   involved     any    designing,

conceptualization of the advertising content and that the activity is

limited to printing as per the contents supplied by the customers and

after placing reliance upon the Trade Notice dated 16.08.1999 and the

Circular dated 23.08.2007, held that the activity undertaken by the

respondent would not fall within the definition of „advertising agency‟.

22.   In William Lea (India) Pvt. Ltd. versus Commissioner of C.

Ex., Chennai-IV5, a division bench of the Tribunal held that where

the basic marketing or promotional material as per the approved

design layout has been provided by the Reader‟s Digest to the

appellant therein for getting them printed, and the appellant was only

required to procure material on which it was to be printed, it would

not mean that the service provided by the appellant would fall within

the definition of „advertisement agency‟. The relevant portion of the

decision is reproduced below:

                  "5.3 The consistent stand of the appellants right from the
                  reply to the SCN is that contract from Reader‟s Digest is
                  for sourcing the paper, card, envelopes, cover, etc., from
                  the market, preparing personalized letters as per the
                  design   given   by   Reader‟s    Digest   and   then   mailing



5.    2019 (25) G.S.T.L. 433 (Tri. - Chennai)
                           16
                                                               ST/23542/2014


materials to their customers; that they are not engaged in
preparation or display of advertisement; that they were
only acting as organizing agents; that they had only
purchased paper, card, envelope, cover, etc., from the
market and personalized letter effect was provided by
another service provider; that finally they had only mailed
the said letter to the clients of Reader‟s Digest. We find
that the findings of the adjudicating authority in this
regard are seen in paragraph 11(iii) as under:

     (iii) As per the agreements and periodical
     work orders, the assessee has undertaken to
     print in paper the subject matter of Reader‟s
     Digest‟s marketing or promotional material as
     per the approved design layout and mail the
     material to customers as per the mailing
     schedule    given    by   „Reader‟s      Digest‟.   The
     assessee had provided services of procurement
     of material including paper, personalizing the
     papers, get printed the subject matter, quality
     control     of      the    final      product       and
     posting/dispatching the material as per the
     mailing schedule. For providing the above
     services,   the     assesssee      has     outsourced
     activities such as printing, scoring, inserting in
     covers, etc. Further they have deputed a
     person for co-ordinating the entire operations
     with the vendors and Reader‟s Digest.

Having made these observations and analyzed the
definitions of "advertising agency service", "business
auxiliary service" and mailing list compilation and
mailing service", the adjudicating authority concludes,
in the same paragraph, that service provided by
appellants to Reader‟s Digest merits classification as
taxable services provided by an advertising agency in
relation to the advertisement under Section 65(105)(e)
of the Act.

5.4. We are unable to fathom these conclusions of the
lower appellate authority. Surely it cannot be said of
the appellants that they had prepared advertising
material on their own. On the other hand, the facts
clearly indicate that the basic market promotional
material as per the approved design lay out by Reader‟s
Digest had been given to the appellants for getting
                                         17
                                                                               ST/23542/2014


              them printed in approved material. Appellants were
              only required to procure the material including paper,
              get the subject matter printed on to such paper with
              personalization for individual clients and post/despatch
              the material as per the mailing schedule. It cannot also
              be said of the appellants that they were engaged in
              display or exhibition or for that matter that they were
              „Advertising Consultant‟ for Reader‟s Digest."


23.   In Zee Telefilms Ltd. versus Commissioner of C. Ex.

(Appeals), Mumbai-IV6, the Tribunal emphasized that the definition

of „advertising agency cannot be read literally out of context and the

relevant portion of the decision is reproduced below:

                    "Therefore, the definition of         „advertising agency‟
              cannot be read literally and out of context, if done so then
              every person some way connected with an advertisement
              will be advertising agency. That cannot be and is not the
              coverage of the Service Tax envisaged. In the present
              case,    one   cannot   ignore       term   being      defined    i.e.
              „advertising agency‟ and proceed to levy service tax on-
                   (i) any commercial concern.
                   (ii) providing service connected with making,
                      preparation,    display       or    exhibition      of
                      advertisements.

                   If the definition is read in isolation and in an all
              encompassing        manner     out    of    context,     then     any
              person/company employing cameraman connected with
              shooting of advertisement film will become an advertising
              agency. A caterer supplying tea and biscuits during the
              production of advertising film will also become a person
              connected with preparation of advertisement and became
              an    advertising   agency.    Similarly,    a   lawyer    advising
              whether advertising film will be violating copyright law or
              other laws relating to obscenity etc. would be treated as
              advertising agent. Similarly a broadcaster (on radio or
              television) of an advertisement will become an advertising
              agency, or a cinema hall flashing an advertisement or
              newspaper/magazine publishing an advertisement will
              become an advertising agency. Such absurdities, from an



6.    2006 (4) S.T.R. 349 (Tri. - Mumbai)
                                          18
                                                                        ST/23542/2014


             interpretation have to be avoided, the term „service
             connected with‟ used in the definition of "Advertising
             Agency" is to be understood in context of and in a
             restrictive manner."


24.   Learned authorised representative appearing for the appellant,

however, placed reliance upon the judgment of the Kerala High Court

in Zodiac Advertisers. The High Court held that all commercial

concerns   engaged     in   any     of        the   activities     connected   with

advertisement, which includes making, preparation displaying or

exhibition of advertisement, answer the description of advertising

agency. The High Court also distinguished the Circular dated

16.08.1999 by observing that in the present case the respondent was

not engaged in printing work only.

25.   It further needs to be noticed that against the decision of the

High Court in Zodiac Advertisers, the department filed an appeal

before the Supreme Court and the Supreme Court set aside the order

passed by the Tribunal as well as the High Court. The Supreme Court

remitted the matter to the Tribunal to examine whether the appellant

undertook the work of conceptualising, visualising and creating the

advertisement or whether it was only complying with the instructions

of the clients. The relevant portion of the judgment of the Supreme

Court is reproduced below:

             "2. Having heard learned counsel on both sides, we
             are of the view that an important question of law does
             arise in this case, namely, whether an assessee comes
             within the definition of the word „advertising agency‟ as
             defined in Section 65(3) of the Finance Act, 1994 as
             amended.

             3.   However, on perusing the record, we find that
             material documents, particularly, orders and purchase
             materials, books of accounts etc., were not placed
             before   the   Tribunal/Adjudicating      Authority    despite
                                              19
                                                                              ST/23542/2014


              being called upon to do so. There is a specific finding to
              that effect in the High Court‟s Order impugned herein.

              4.   In the circumstances, we set aside the order of the
              High Court as well as that of the Tribunal, giving final
              opportunity to the appellant herein to produce all the
              relevant records particularly to show the nature of the
              work   which        the    appellant   specifically   undertakes.
              Accordingly, the matter stands remitted to the
              Tribunal      which        would    examine      whether       the
              appellant     herein is undertaking the                 work    of
              conceptualising,           visualising    and    creating      the
              advertisement or whether it is only complying
              with the instructions of its clients. This aspect
              needs further details. Therefore, we are setting aside
              the order of the Tribunal as well as the order of the
              High Court.

              5.   Subject to above, Civil Appeal stands disposed of.
              Assessee will pay cost of Rs. 10,000/- (Rupees Ten
              Thousand)      to    the     Department     as   cost   condition
              precedent."
                                                       (emphasis supplied)


26.   The Supreme Court, therefore, in the aforesaid judgment,

emphasised that there would be difference if a person is engaged in

proving any service connected with the making or preparation of the

advertisement and a case where a person merely complies with the

instruction of the clients for printing the contents supplied by the

client.

27.   In so far as levy of service tax on printing activity is concerned,

the Commissioner was justified in holding that it would not be

subjected to levy of service tax. In the first instance the activity of

printing of advertisement content on PVC material which results into

printed PVC flex or PVC board would amount to manufacture and,

therefore, would not be leviable to service tax. Secondly, the
                                    20
                                                            ST/23542/2014


appellant has not challenged the findings of the adjudicating authority

on this aspect.

28.   For the post 01.07.2012 period, the Commissioner has held that

the activity undertaken by the respondent being merely transfer of

title on goods by sale and subjected to Sales Tax/VAT on the full

value, would be excluded from the scope of service tax under section

65B (44)(a)(1) of the Finance Act.

29.   The sale of the product has not been disputed and even

otherwise no grounds have been raised in the present appeal to assail

this part of the order of the Commissioner. There is also force in the

submission of learned counsel for the respondent that even the show

cause notice does not indicate why service tax would be leviable for

the period post 01.07.2012.

30.   Thus, for all the reasons stated above, the order dated

18.07.2014 passed by the Commissioner does not call for any

interference in this appeal. The appeal is, accordingly, dismissed.



                   (Order pronounced on 14.09.2022)




                                             (JUSTICE DILIP GUPTA)
                                                        PRESIDENT




                                                  (P. V. SUBBA RAO)
                                               MEMBER (TECHNICAL)
JB
                                        21
                                                              ST/23542/2014


 CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL
                    HYDERABAD

                           REGIONAL BENCH

             SERVICE TAX APPEAL NO. 23542 OF 2014


Commissioner of Central Excise,                          ...Appellant
Hyderabad-III Commissionerate,
Hyderabad


                                     versus


Macro Media Digital Imaging Pvt. Ltd.                    ...Respondent
147/D, Secto-I, Line-1, Phase-II,
Cherlapally IDA, Hyderabad- 500051
(Telangana State)


Appearance

Mr. V.R. Pavan Kumar, Authorized Representative of the Department
Mr. S. Thirumalai, Advocate for the Respondent

CORAM:

HON'BLE MR. JUSTICE DILIP GUPTA, PRESIDENT
HON'BLE MR. C.J. MATHEW, MEMBER (TECHNICAL)


                                              Date of Hearing: 04.05.2022



                                     ORDER

(Order pronounced on 14.09.2022) (JUSTICE DILIP GUPTA) PRESIDENT (C.J. MATHEW) MEMBER (TECHNICAL) JB