HT MEDIA LIMITEDversusPRINCIPAL COMMISSIONER DELHI SOUTH GOODS AND SERVICE TAX

                  [2026] 1 S.C.R. 904 : 2026 INSC 66

                         HT Media Limited
                                v.
           Principal Commissioner Delhi South Goods and
                           Service Tax
                (Civil Appeal No(s). 23525-23526 of 2017)
                               16 January 2026
             [J.B. Pardiwala* and K.V. Viswanathan, JJ.]


                           Issue for Consideration
       Whether the fee paid by the appellant to the personalities/speakers,
       through their booking agents, is liable to Service Tax under the
       reverse charge mechanism, more particularly under the taxable
       category of “Event Management Service” u/ss.65(40) and 65(41)
       r/w. s.65(105)(zu) respectively of Chapter V of the Finance Act.

                                  Headnotes†
       Finance Act, 1994 – s.65(105)(zu) r/w. ss.65(40) and 65(41) –
       The appellant assessee conducted annual Hindustan Times
       Leadership Summit (the Summit) – Speakers were invited from
       outside India to address the Summit – The appellant entered
       into contracts with booking agents such as the Washington
       Speakers Bureau and Harry Walker Agency to book speakers –
       Show cause notices were issued under the Finance Act inter
       alia proposing to impose Service Tax on fees paid to the
       speakers through the booking agents under the category of
       “Event Management Service” – The Commissioner vide the
       Order-in-Original dated 13.02.2014, the demand of Service
       Tax invoking the extended period of limitation u/s.73 of the
       Finance Act with interest and penalty, was confirmed – While
       the Tribunal set aside the invocation of the extended period of
       limitation, the demand under the normal period of limitation
       came to be affirmed by the Tribunal under the category of
       “Event Management Service” – Correctness:
       Held: The agreements of the assessee with the agents are part
       of the record of the present appeals – A bare perusal of these
       agreements would indicate that they are in the nature of booking
       a particular speaker for the Summit – The tenor of the contracts

* Author
[2026] 1 S.C.R.                                                           905

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

     and the declaration given by the agents clearly indicate that the
     services rendered by such agents to the assessee were in the
     nature of booking the speakers for the event to be organized by
     the assessee – The contracts were entered into with the agents
     qua each speaker laying down the modalities of his/her visit and
     consideration for the same – Such services cannot be equated with
     “event management service” which has been statutorily defined
     to mean “any service provided in relation to planning, promotion,
     organizing or presentation of any arts, entertainment, business,
     sports, marriage or any other event and includes any consultation
     provided in this regard” – The contract of the asseessee with
     the booking agents was not for “management of an event” but
     for booking of the speaker – The presence of the speaker is
     essential for the event cannot be disputed – The speaker does
     not plan, promote, organize or present the event – Thus, the
     speaker, is neither an “event manager” nor does he provide an
     “event management service” – Similarly, the booking agent who
     merely books the speaker also acts in the capacity of an agent or
     representative for agreeing to the terms of the speakers’ presence
     at the event – Participation in the event cannot be considered as
     management of the event – This precisely is the fundamental error
     committed by the revenue as well as by the Tribunal while imposing
     Service Tax on the service in question under the category of “event
     management service” – Even if this test of interpretation of sales
     tax statutes is applied for interpreting the clause for imposing
     Service Tax, the contract in question cannot be considered to be
     commonly understood as that of event management – Thus, the
     impugned judgment and order passed by the Tribunal is hereby
     set aside. [Paras 37, 39, 41, 48, 49]

                             Case Law Cited
     Shiv Steels v. State of Assam, 2025 SCC Online SC 2006 – relied
     on.
     International Merchandising Company, LLC (Earlier known as
     International Merchandising Corporation) v. Commissioner,
     Service Tax, New Delhi [2022] 8 SCR 872 : (2023) 3 SCC 641 –
     distinguished.
     Bharti Cellular Limited v. Assistant Commissioner of Income Tax
     [2024] 2 SCR 1001 : (2024) 8 SCC 608; UOI v. Future Gaming
     Solutions Private Limited [2025] 2 SCR 756 : (2025) 5 SCC
906                                                          [2026] 1 S.C.R.

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       601; Commissioner of Sales Tax v. Jaswant Singh Charan Singh
       [1967] 2 SCR 720 : 1967 SCC Online SC 154; Indo International
       Industries v. Commissioner of Sales Tax [1981] 3 SCR 294 : (1981)
       2 SCC 528 – referred to.

                                  List of Acts
       Finance Act, 1994.

                               List of Keywords
       Service Tax; Event Management; Event Management Service;
       Event Manager; Speakers; Summit; Booking agents; Revenue
       implication; Reverse Charge Mechanism; Taxable services; Strict
       Interpretation; Common Parlance Test; Four Corners of the Statute.

                              Case Arising From
       CIVIL APPELLATE JURISDICTION: Civil Appeal No(s). 23525-
       23526 of 2017
       From the Judgment and Order dated 31.08.2017 of the Custom
       Excise Service Tax Appelate Tribunal in FO Nos. 56358 and 56359
       of 2017

                            Appearances for Parties
       Advs. for the Appellant(s):
       Ashok Dhingra, Karan Bharihoke, Ms. Sonia Gupta.
       Advs. for the Respondent(s):
       V.C. Bharathi, Gurmeet Singh Makker, S.K.singhania, P.V.
       Yogeshwaran, Annirudh Sharma II.

                  Judgment / Order of the Supreme Court

                                  Judgment

       J.B. Pardiwala, J.

1.     Since the issues involved in both the captioned appeals are the
       same, the challenge is also to the self-same judgment passed by
       the Tribunal and the parties are also the same, those were taken up
       for hearing analogously and are being disposed of by this common
       judgment and order.
[2026] 1 S.C.R.                                                         907

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

2.   These appeals arise from the common judgment and order passed by
     the Customs, Excise and Service Tax Appellate Tribunal, New Delhi
     (for short, the “CESTAT”) dated 31.08.2017 in Service Tax Appeal
     Nos. 52881 & 52888 of 2014 respectively, by which the appeals filed
     by the appellant herein came to be disposed by the Tribunal holding
     that the appellants herein are liable to pay Service Tax under the
     category of “event management service” for the period covered within
     the normal limitation. At the same time, the Tribunal also held that
     the demand of Service Tax in respect of management consultancy
     service and business support service, and interest liability for entries
     with reference to associated enterprise were not sustainable in law.

     FACTUAL MATRIX:-
3.   The appellant assessee conducted annual Hindustan Times
     Leadership Summit (hereinafter referred to as, “the Summit”).
     Speakers were invited from outside India to address the Summit.
     The appellant entered into contracts with booking agents such as
     the Washington Speakers Bureau and Harry Walker Agency to book
     speakers such as Mr. Tony Blair, Mr. Jerry Linenger and Mr. Al Gore.
4.   Show cause notices were issued under the Finance Act, 1994
     (hereinafter referred to as “the Finance Act”) inter alia proposing
     to impose Service Tax on fees paid to the speakers through the
     booking agents under the category of “Event Management Service”
     under Section 65(105)(zu) read with Sections 65(40) and 65(41)
     respectively of Chapter V of the Finance Act by invoking the extended
     period of limitation.
5.   The show cause notices were adjudicated by the Commissioner and
     ultimately vide the Order-in-Original dated 13.02.2014, the demand of
     Service Tax invoking the extended period of limitation under Section
     73 of the Finance Act with interest and penalty, was confirmed.
6.   The appellant assessee being dissatisfied with the Order-in-Original
     passed by the Commissioner referred to above, went in appeal
     before the Tribunal. While the Tribunal set aside the invocation of the
     extended period of limitation, the demand under the normal period
     of limitation came to be affirmed by the Tribunal under the category
     of “Event Management Service”.
7.   In such circumstances referred to above, the appellant is here before
     this Court with the present appeals.
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       SUBMISSIONS ON BEHALF OF THE APPELLANT:-
8.     Mr. Ashok Dhingra, the learned Counsel appearing for the appellant
       vehemently submitted that the Tribunal committed a serious error in
       passing the impugned order affirming the demand under the normal
       period of limitation. It was argued vehemently that no service could
       be said to have been provided by the agents to the appellant.
9.     The learned Counsel argued that there was no arrangement between
       the appellant and the agents for providing of any service for the
       Summit to the appellant. The agents, being lecture booking agents
       of the speakers, dealt with the appellant on behalf of the speakers.
10. It was further argued that the speakers, being senior politicians
    and former heads of States could be booked only through their
    respective agents, who negotiate & execute contracts, and collect
    an appearance fee on behalf of the speakers. The agents were paid
    by the speakers for the services rendered to the speakers, which
    fact has been confirmed by both the Washington Speakers Bureau
    and Harry Walker Agency respectively.
11. It was argued that for Section 65(40) and Section 65(105)(zu) of the
    Finance Act respectively to apply, an activity must have the following
    essential ingredients cumulatively to be taxable as service under
    taxable category of Event Management thereof:
       (a)   The person providing the Service must be an Event Manager,
             as defined in Section 65(41) read with the TRU Circular dated
             08.08.2002.
       (b)   Such Event Manager should be engaged in providing service
             to any person, and
       (c)   Such service should be in relation to event management, i.e.,
             planning, promotion, organizing, or presentation of any arts,
             entertainment, business, sports, marriage or any other event
             and includes any consultation provided in this regard.
12. The learned Counsel submitted that the TRU Circular dated
    08.08.2002 clarified that Event Manager is a person who is engaged
    in managing the venue for an event, including decoration of sets,
    mandap, chair, table, barricades, sound, light video, electricals,
    security, communication, invitations to the event/sale of tickets and
[2026] 1 S.C.R.                                                         909

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

     publicity of the event; & also has to manage stage show, artist,
     musician, choreographers & other miscellaneous items of work for
     holding of an event.
13. It was also argued that in the instant case the agents:
     (a)   were neither event managers, nor were engaged in providing
           any service to the appellant. The agreements were signed by
           them as lecture booking agents of the speakers, on their behalf;
     (b)   were not engaged in managing venue, decoration of sets,
           barricades, sound, light, security, communication, sale of tickets
           or publicity;
     (c)   had nothing to do with planning, promotion, organization, or
           presentation of the Summit, and
     (d)   did not provide any consultation to the appellant qua the Summit.
14. In the last, it was argued that in the decision rendered in International
    Merchandising Company, LLC (Earlier known as International
    Merchandising Corporation) v. Commissioner, Service Tax,
    New Delhi reported in 2023 (3) SCC 641, this Court has held, in
    an identical fact situation, that the service falls under the category
    of Manpower Recruitment or Supply Agency Service, classifiable
    under Section 65(105)(k). Consequently, the very same service
    cannot be classified by the Revenue under Section 65(105)(zu) as
    Event Management Services.
15. The learned Counsel in support of his aforesaid submissions placed
    strong reliance on the following decisions:
           (a) Bharti Cellular Limited v. Assistant Commissioner
           of Income Tax reported in (2024) 8 SCC 608.
           (b) UOI v. Future Gaming Solutions Private Limited
           reported in (2025) 5 SCC 601.
16. In such circumstances referred to above, the learned Counsel prayed
    that there being merit in his appeals, those may be allowed and the
    impugned order passed by the Tribunal be set aside.

     SUBMISSIONS ON BEHALF OF THE REVENUE:
17. On the other hand, Mr. V. Chandrashekara Bharathi, the learned
    Counsel appearing for the Revenue would submit that the primary
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       contention of the appellant that the booking agents are the agents of
       the speakers and there is no service contract between the booking
       agents and the appellant, deserves to be rejected for the following
       reasons:
       (a)   For a Principal Agent relationship to arise, it is a condition
             precedent that the booking agents represent themselves as
             the speaker’s agent to the appellant. To the contrary, in the
             contract between the appellant and Harry Walker agency, it is
             explicitly mentioned that the booking agent is an independent
             contractor and will not be responsible for the actions of the
             speaker. There was no representation whatsoever that the
             booking agent was representing the speaker in concluding the
             contract with the appellant.
       (b)   To the contrary, the booking agent would ensure that the
             speaker appears in the Summit organized by the appellant
             and is concluding the contracts in their individual capacity for
             the purpose of ensuring the speakers’ presence in the Summit.
       (c)   Merely because the agencies abroad represented themselves as
             ‘booking agents’, they would not automatically become agents
             of the speakers. For such an agency to arise, the contract must
             be in such a way that the booking agents conclude the contracts
             by way of an express authorization granted by the speakers to
             the booking agents. Such an authorization is conspicuous by
             its absence in the present case.
       (d)   If the booking agents are indeed agents of the speakers as
             submitted by the appellant, there was no requirement for the
             booking agents to distance themselves from the speakers
             action, since their role will be limited to merely concluding the
             contract and will have no liability at all, since it is actually the
             speaker himself concluding the contract in the eyes of the law.
       (e)   Lastly, the consideration that was paid by the appellant to the
             booking agent was not a payment made to the speaker directly.
             It was a payment made to the booking agent for procuring
             the speaker. Consequently, the gross amount charged by the
             booking agent would be the taxable value, on which the rate
             of Service Tax would apply.
[2026] 1 S.C.R.                                                        911

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

     (f)   As a result, on account of the lack of representation by
           the booking agents to the appellant that they were indeed
           representing the speakers while concluding the contract and
           the lack of express authorization issued by the speakers to the
           booking agents to conclude contracts on their behalf, the booking
           agents cannot be treated as mere agents of the speakers.
18. The Revenue further contended that the submission of the appellant
    that the contours of Section 65(105)(zu) are not satisfied deserves
    to be rejected for the following reasons:
     (a)   Any service provided or to be provided to any person by an
           event manager in relation to event management is a taxable
           supply under Section 65(105)(zu).
     (b)   An ‘event manager’ means any person who is engaged in
           providing any service in relation to event management in any
           manner, under Section 65(41).
     (c)   ‘Event Management’ means any service provided in relation
           to planning, promotion, organizing or presentation of any arts,
           entertainment, business, sports, marriage or any other event
           and includes any consultation provided in this regard, under
           Section 65(40).
     (d)   In short, the appellant must satisfy the definition of the event
           manager and must provide a service in relation to the event
           management, for the charge to be successful.
     (e)   The speakers cannot be identified separately from the Summit.
           It is the speakers that constitute the Summit. There would be
           no Summit if not for the speakers’ presence. In other words,
           the speakers by themselves become the event. The role of the
           booking agents must be examined in this context.
     (f)   By ensuring the speakers’ presence for a consideration, the
           booking agents undoubtedly rendered a service in relation to the
           planning, promotion, organizing or presentation of the Summit.
           It was integral for the appellant to procure the speakers since
           without them the event would be without any significance, and
           it was the booking agents that ensured speakers’ presence.
           Consequently, the booking agents would become event
           managers and by procuring the speakers’ presence and ensuring
912                                                          [2026] 1 S.C.R.

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             that they deliver the lecture at the Summit, they have provided
             an event management service, liable to tax under Section
             65(105)(zu).
19. In the last, it was argued that the decision of this Court in International
    Merchandising Company LLC (supra) has no application to the
    present case.
20. In such circumstances referred to above, the learned counsel prayed
    that there being no merit in the appeals those may be dismissed

       ANALYSIS:-
21. Having heard the learned Counsel appearing for the parties and
    having gone through the material on record, the only question that
    falls for our consideration is whether the fee paid by the appellant to
    the personalities/speakers, through their booking agents, is liable to
    Service Tax under the reverse charge mechanism, more particularly
    under the taxable category of “Event Management Service” under
    Sections 65(40) and 65(41) read with Section 65(105)(zu) respectively
    of Chapter V of the Finance Act?
22. The aforesaid issue falls for our consideration for the period of demand
    between October, 2009 and March, 2012. The revenue implication is
    to the tune of Rs. 60,56,180/- (Rupees sixty lakh fifty-six thousand
    one hundred eighty).
23. Before adverting to the rival submissions canvassed on either side,
    we must look into few relevant provisions of the Finance Act.
24. During the period of dispute and up to 30.06.2012, Service Tax
    was levied on various categories of taxable services defined in the
    Finance Act i.e., under the positive definition of taxable services [w.e.f.
    01.07.2012 the negative list of services regime was introduced under
    the Finance Act, where all services were taxable except services
    in the negative list or those exempted by notification issued by the
    Central Government], the relevant provisions of which are:
       (a)   Section 66 – provided for levy of Service Tax on value of
             taxable services.
       (b)   Section 66A – provided for levy of Service Tax on taxable
             services provided from outside India and received by a person
             in India under the reverse charge mechanism.
[2026] 1 S.C.R.                                                            913

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

     (c)   Various sub-Sections of Section 65 – provided definition of
           individual taxable services, which were amended from time to
           time by an amending Act, and liability to Service Tax.
     (d)   Section 65A – provided for the classification of taxable services,
           as follows:
                “65A. Classification of taxable services –
                (1) For the purposes of this chapter, classification
                of taxable services shall be determined according
                to the terms of the sub- clauses (105) of section 65;
                (2) When for any reason, a taxable service is prima
                facie, classifiable under two or more sub-clauses
                of clause (105) of section 65, classification shall be
                effected as follows :-
                (a) the sub-clause which provides the most specific
                description shall be preferred to sub-clauses providing
                a more general description;
                (b) composite services consisting of a combination
                of different services which cannot be classified in the
                manner specified in clause (a), shall be classified
                as if they consisted of a service which gives them
                their essential character, in so far as this criterion is
                applicable;
                (c) when a service cannot be classified in the
                manner specified in clause (a) or clause (b), it shall
                be classified under the sub-clause which occurs
                first among the sub-clauses which equally merits
                consideration;]
                4(3) The provisions of this section shall not apply
                with effect from such date as the Central Government
                may, by notification, appoint.”
     (e)   Section 73 – provided for recovery of Service Tax not levied
           or paid or short levied or short paid or erroneously refunded.
25. Section 65(41) of the Finance Act defined ‘event manager’ as
    follows:
914                                                       [2026] 1 S.C.R.

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          “‘event manager’ means any person who is engaged in
          providing any service in relation to event management in
          any manner”
26. Section 65(40) of the Finance Act defined ‘event management’ as
    follows:
          “‘event management’ means any service provided in
          relation to planning, promotion, organizing or presentation
          of any arts, entertainment, business, sports, marriage or
          any other event and includes any consultation provided
          in this regard”
27. Section 65(105)(zu) of the Finance Act, defined taxable service as
    follows:
          “65. … (105) “taxable service” means any service provided
          or to be provided, -

                           xxx        xxx        xxx
          (zu) to any person, by an event manager in relation to
          event management”
28. The Tax Research Unit of the Board vide Circular issued under F.
    No. B11/1/2002-TRU dated August 8, 2002 (hereinafter, the “Circular
    dated 08.08.2002”) clarified inter alia in relation to Event Management
    Service as thus:
          “2. As per clause (34), “event management” means
          any service provided in relation to planning, promotion,
          organizing or presentation of any arts, entertainment,
          business, sports or any other event and includes any
          consultation provided in this regard. Vide clause (90)(zu),
          taxable service means any service provided to a client,
          by an event manager in relation to event management.
          Event manager has been defined in clause (35) as any
          person who is engaged in providing any service in relation
          to event management in any manner.
          3. An event manager is hired to execute an event such
          as product launch of any corporate, promotional activities,
          concerts/ rock show, official meets, award functions,
          beauty pageants, entertainment events, exhibitions, private
[2026] 1 S.C.R.                                                          915

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

           functions, and sports events etc. Event manager uses his
           expertise and ideas to manage an event. Event manager
           is supposed to manage a venue, sets including decoration
           of sets, mandap, chair, table, barricades, sound, light
           video, electricals, security, communication, invitations to
           the event/ sale of tickets and publicity of the event. He
           has also to manage the stage show, artist, musician,
           choreographers and other miscellaneous items for holding
           of event. All services provided by the event manager are
           liable to service tax. This also covers any consultation
           provided for organizing an event....”
29. Section 65(68) of the Finance Act defined ‘Manpower Recruitment
    or Supply Agency Service’ as follows:
           “Manpower recruitment or supply agency” means
           any person engaged in providing any service, directly
           or indirectly, in any manner for recruitment or supply of
           manpower, temporarily or otherwise, to any other person”.
30. Section 65(105)(k) of the Finance Act defined ‘taxable service’ as
    follows:
           “65. … (105) “taxable service” means any service provided
           or to be provided,-
           (k) to any person, by a manpower recruitment or supply
           agency in relation to the recruitment or supply of manpower,
           temporarily or otherwise, in any manner;
           Explanation — For the removal of doubts, it is hereby
           declared that for the purposes of this sub-clause,
           recruitment or supply of manpower includes services
           in relation to pre-recruitment screening, verification of
           the credentials and antecedents of the candidate and
           authenticity of documents submitted by the candidate;”
31. Thus, the essential ingredients for levy of Service Tax during the
    Period of Dispute on any activity were:
     (a)   Such activity should be service provided in India;
     (b)   Provided by one person to another;
     (c)   For a consideration;
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       (d)   Such service must fall under any of the defined taxable category
             of service i.e., under the positive definition of taxable services
             under the Finance Act and made liable to Service Tax as taxable
             service under various clauses of Section 65(105). Thus, for
             levy of Service Tax, taxable category of services of the Finance
             Act under which such service is liable to Service Tax has to be
             determined and proposed in the show cause notice issued by
             the Department; and
       (e)   In case of taxable service provided from outside India to a
             person in India, the recipient of such service is liable to Service
             Tax under the reverse charge mechanism.

       SCHEME OF TAXABILITY
32. For the purpose of deciding the pivotal issue, it is first necessary
    to discuss the scheme of taxability under the Finance Act during
    the relevant period. The period of dispute is from October 2009 to
    March 2012.
33. It is not in dispute that during such period prior to 1.7.2012, the
    Service Tax was leviable only on the positive list of services as
    enumerated in Section 65(105) of Chapter V of the Finance Act. If
    the services strictly fall within such list, then they are taxable and if
    not, then no tax can be imposed on such services.
34. The only clause of the taxable list of services which is being invoked
    by the revenue in the present case for imposing tax is Section 65(105)
    (zu) of the Finance Act.
35. The expressions “event management” and “event manager”
    respectively occurring in Section 65(105)(zu) are defined under
    Section 65(40) and Section 65(41) of the Finance Act respectively.
36. The impugned levy of Service Tax can be sustained only if the service
    in question falls within the four corners of “event management” by
    an “event manager”.

       WHETHER THE PROVISION COVERS THE SERVICE IN
       QUESTION?
37. The agreements of the assessee with the agents are part of the record
    of the present appeals. A bare perusal of these agreements would
    indicate that they are in the nature of booking a particular speaker for the
[2026] 1 S.C.R.                                                          917

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

     Summit. It provides for conditions relating to travel and accommodation
     of the speaker as well as the schedule of the speaker during his/her
     visit for the Summit. The contract also provides for the commitments
     made by the speakers. For instance, in the contract of the assessee
     with the Washington Speakers Bureau for Mr. Tony Blair, the contract
     refers to the likely duration of Mr. Blair’s speech and Question & Answer
     session. It also provides for the locations where and the duration for
     which media interaction with Mr. Blair can take place. The contract
     further briefly touches upon the topics of interaction.
38. Moreover, the appellant assessee has also placed on record
    declarations from the agents that they rendered services to the
    assessee as booking agents and that the payment for appearance
    of speakers was collected by the agents under instructions and on
    behalf of the speakers in terms of the contracts with the speakers.
39. The tenor of the contracts and the declaration given by the agents
    clearly indicate that the services rendered by such agents to the
    assessee were in the nature of booking the speakers for the event
    to be organized by the assessee. The contracts were entered into
    with the agents qua each speaker laying down the modalities of his/
    her visit and consideration for the same. Such services cannot be
    equated with “event management service” which has been statutorily
    defined to mean “any service provided in relation to planning,
    promotion, organizing or presentation of any arts, entertainment,
    business, sports, marriage or any other event and includes any
    consultation provided in this regard”. The contract of the asseessee
    with the booking agents was not for “management of an event” but
    for booking of the speaker.
40. The entire submission of the revenue focuses on the aspect as to
    whether a “principal-agent” relationship is established between the
    speaker and the booking agent. However, we are of the view that
    this is wholly irrelevant for the present controversy. The issue is not
    whether the relationship between the speaker and the booking agent
    is that of “principal-agent” or not. The issue is whether the contract
    constitutes “event management service”. As discussed hereinbefore,
    the contract is for booking of speaker and not for event management
    and therefore, the levy of tax on such contract under the category
    of “Event Management Service” should fail.
41. The further argument of the revenue that, without the speaker the
    event would be devoid of any significance and therefore, the service
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       in question is an “Event Management Service”, also deserves to be
       rejected. That the presence of the speaker is essential for the event
       cannot be disputed. However, whether the service of the speaker or
       the agent on behalf of the speaker can be considered to be “event
       management service” is altogether a different issue. The speaker
       does not plan, promote, organize or present the event. Thus, the
       speaker, is neither an “event manager” nor does he provide an “event
       management service”. Similarly, the booking agent who merely books
       the speaker also acts in the capacity of an agent or representative
       for agreeing to the terms of the speakers’ presence at the event.
       Participation in the event cannot be considered as management of
       the event. This precisely is the fundamental error committed by the
       revenue as well as by the Tribunal while imposing Service Tax on the
       service in question under the category of “event management service”.

       PRINCIPLE OF STRICT INTERPRETATION OF TAXING STATUTE
       WELL ESTABLISHED
42. The principle of strict interpretation of a taxing statute, particularly
    in the context of charging provisions, is well established. We may
    refer to the recent decision in the case of Shiv Steels v. State of
    Assam reported in 2025 SCC Online SC 2006 wherein this Court
    observed as under:
            “14. In construing fiscal statutes and in determining the
            liability of a subject to tax one must have regard to the
            strict letter of law. If the revenue satisfies the court that
            the case falls strictly within the provisions of the law, the
            subject can be taxed. If, on the other hand, the case is
            not covered within the four corners of the provisions of
            the taxing statute, no tax can be imposed by inference or
            by analogy or by trying to probe into the intentions of the
            legislature and by considering what was the substance
            of the matter.”
                                                  (Emphasis supplied)

       CIRCULAR OF CBIC ALSO SUPPORTS THE ASSESSEE
43. The reliance placed by the assessee on Circular dated 8.8.2002 is
    also well founded. At the cost of repetition, we reproduce the relevant
    extract of the circular as under:
[2026] 1 S.C.R.                                                            919

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

           “3. An event manager is hired to execute an event such
           as product launch of any corporate, promotional activities,
           concerts/rock show, official meets, award functions, beauty
           pageants, entertainment events, exhibitions, private
           functions and sports events, etc. Event manager uses his
           expertise and ideas to manage an event. Event manager is
           supposed to manage a venue, sets including decoration of
           sets, mandap, chair, table, barricades, sound, light, video,
           electricals, security, communication, invitation to the event/
           sale of tickets and publicity of the event. He has also to
           manage the stage show, artist, musician, choreographers
           and other miscellaneous items for holding of event. All
           services provided by the event manager are liable to
           service tax. This also covers any consultation provided
           for organizing and event…”
44. Thus, what is sought to be covered is the service of management
    or organizing of the event, and the revenue cannot be allowed to
    stretch the application of such a clause beyond its contours.
45. Having said so, we are also of the view that the classification dispute
    raised by the appellant, pursuant to the decision of this Court in
    International Merchandising Company LLC (supra), deserves to
    be rejected for the following reasons:
     (a)   The appellant is correct insofar as the following is concerned:
           (i)    Prior to 01.07.2012, the Service Tax regime had specific
                  entries for each service. In other words, without a particular
                  classification, the Revenue cannot tax any service.
           (ii)   Consequently, a particular service cannot have two
                  classifications and has to be traced under a specific sub-
                  clause of Section 65(105).
           (iii) Since the disputed period is prior to 01.07.2012, the
                 service provided by the booking agents to the appellant
                 needs to be classified under a specific sub-clause. As a
                 result, if the appellant succeeds on the ground that the
                 service provided by the booking agents is a manpower
                 supply service, as held in the aforesaid judgment of this
                 Court, the Revenue cannot classify the same service as
                 event management simultaneously.
920                                                           [2026] 1 S.C.R.

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       (b)   Though at first glance, the facts in International Merchandising
             Company LLC (supra) seem to overlap with the present case,
             a subtle yet significant difference distinguishes the present case
             from the facts of International Merchandising.
       (c)   In International Merchandising Company LLC (supra), the
             appearance and presence of Mr. Vijay Amritraj was ensured
             by the service provided in relation to the Chennai Open, which
             was the event. He was to make appearances and participate
             in the charity opening match. What is crucial to note is that Mr.
             Amritraj had no relevance whatsoever to the main event i.e.,
             Chennai Open. With or without Mr. Amritraj, the main event
             i.e., Chennai Open, would have continued without any hiccups.
             This would show that the presence of Mr. Amritraj was merely
             ancillary to the main event.
       (d)   To the contrary, in the present case, the booking agents that
             ensured the speakers’ presence directly played an integral
             role in the event itself. Without their involvement, the Summit
             conducted by the appellant would not have taken place since
             the event and the speakers cannot be separated from each
             other. The speakers and their lecture constitute the event, and
             the booking agents ensure the event takes place. As a result,
             the speakers’ presence is not ancillary to the main event.
       (e)   Consequently, the judgment in International Merchandising
             Company LLC (supra) is distinguishable from the facts of the
             present case.

       LEVY FAILS EVEN ON APPLICATION OF COMMON PARLANCE
       TEST
46. What is stated in the circular is also the common parlance
    understanding of “event management”. The common parlance test
    has been applied by this Court for determining classification under
    sales tax statutes on various occasions. While deciding whether
    “charcoal” would be included in “coal” it was observed by this Court in
    the case of Commissioner of Sales Tax v. Jaswant Singh Charan
    Singh reported in 1967 SCC Online SC 154 as under:
             “The result emerging from these decisions is that while
             construing the word “coal” in entry 1 of Part III of Schedule
[2026] 1 S.C.R.                                                            921

                        HT Media Limited v.
     Principal Commissioner Delhi South Goods and Service Tax

           II, the test that would be applied is what would be the
           meaning which persons dealing with coal and consumers
           purchasing it as fuel would give to that word. A sales tax
           statute, being one levying a tax on goods, must, in the
           absence of a technical term or a term of science or art, be
           presumed to have used an ordinary term as coal according
           to the meaning ascribed to it in common parlance. Viewed
           from that angle both a merchant dealing in coal and a
           consumer wanting to purchase it would regard coal not in its
           geological sense but in the sense as ordinarily understood
           and would include “charcoal” in the term “coal”.”
                                                  (Emphasis supplied)

47. Similarly, while deciding whether clinical syringes could be considered
    as “glassware” or not, this Court observed in the case of Indo
    International Industries v. Commissioner of Sales Tax reported
    in (1981) 2 SCC 528 as under:
           “It is true that the dictionary meaning of the expression
           “glassware” is “articles made of glass” (see Webster’s
           New World Dictionary). However, in commercial sense
           glassware would never comprise articles like clinical
           syringes, thermometers, lactometers and the like which
           have specialized significance and utility. In popular or
           commercial parlance a general merchant dealing in
           “glassware” does not ordinarily deal in articles like clinical
           syringes, thermometers, lactometers, etc., which articles
           though made of glass, are normally available in medical
           stores or with the manufacturers thereof like the assessee.
           It is equally unlikely that a consumer would ask for such
           articles from a glassware shop. In popular sense when
           one talks of glassware such specialized articles like
           clinical syringes, thermometers, lactometers and the like
           do not come up to one’s mind. Applying the aforesaid
           test, therefore, we are clearly of the view that the clinical
           syringes which the assessee manufactures and sells
           cannot be considered as “glassware” falling within entry
           39 of the First Schedule to the Act.”
                                                  (Emphasis supplied)
922                                                        [2026] 1 S.C.R.

                              Supreme Court Reports


48. Even if this test of interpretation of sales tax statutes is applied for
    interpreting the clause for imposing Service Tax, the contract in
    question cannot be considered to be commonly understood as that
    of event management. The expressions ‘event management’ and
    ‘event managers’ is commonly understood in the sense of appointing
    someone to manage or organize the event. Individual contract for
    booking of persons required for participation in the event are not
    commonly understood as “event management” contracts.
49. In the result, these appeals succeed and are hereby allowed. The
    impugned judgment and order passed by the Tribunal is hereby set
    aside.

       Result of the case: Appeals allowed.




       †
           Headnotes prepared by: Ankit Gyan