Taxablity of comission recived on activation of dth

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KUMAR (Querist)
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15 June 2013 Dear Sir,

Commission Received on DTH Activation and Selling of Currency liable for service tax ?

Please provide detailed info and reference if any

Thanks In Advance

Arun Kumar Singh

Arun Kumar Singh (Expert)
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15 June 2013 Both are taxable services.

KUMAR

KUMAR (Querist)
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17 June 2013 sir,
But came in Mega Exemption notification 25/2012 the commission on selling of sim card and recharge coupons not liable for service tax
my doubt is same is applicable for DTH currencies also ?

Thanks In Advance

Arun Kumar Singh

Arun Kumar Singh (Expert)
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17 June 2013 If services are covered under the mega exemption notification then no need to pay service tax. other than 25/2012-ST are taxable service.

KUMAR

KUMAR (Querist)
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17 June 2013 Sir,
in notification mentioned only about SIM Card & Recharge coupons but not DTH therefore my doubt is Commission received on DTH Activation & Sale of currency of DTH fall with in the meaning of SIM Card and Recharge Coupons

KUMAR

KUMAR (Querist)
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Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)
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26 July 2025 Good question! Here’s a detailed explanation on the **taxability of commission received on DTH activation and sale of DTH currency** under service tax law (pre-GST era):

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### 1. **Mega Exemption Notification 25/2012-ST**

* This notification specifically exempts **commission on sale of SIM cards and recharge coupons** from service tax.
* The exemption is **limited only to telecom SIM cards and recharge coupons**.

### 2. **Does the exemption apply to DTH activation commission and DTH currency sale?**

* **No, the exemption does not cover DTH services** or sale of DTH currency (top-ups).
* The notification explicitly mentions only SIM cards and recharge coupons related to telecom services.
* DTH activation and sale of DTH currency are **distinct services** and **not covered** under the telecom exemption.

### 3. **Taxability of Commission on DTH Activation & DTH Currency Sale**

* Commission earned on **activation of DTH services** is treated as a consideration for providing a service.
* Similarly, commission on **sale of DTH currency (top-up cards or electronic vouchers)** is a service income.
* Therefore, **both are taxable under service tax** as per the classification of services.

### 4. **Relevant Service Tax Heads**

* **DTH activation commission** would typically fall under **“Telecommunication Service”** or possibly **“Business Auxiliary Services”** depending on the contractual arrangement.
* **Sale of DTH currency commission** may also be covered under **“Business Auxiliary Services”** or specific service classification relevant to prepaid recharge.

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### Summary Table:

| Service | Exempt under Mega Notification 25/2012? | Taxability |
| -------------------------------------- | --------------------------------------- | ---------- |
| Commission on sale of SIM cards | Yes | Exempt |
| Commission on sale of recharge coupons | Yes | Exempt |
| Commission on DTH activation | No | Taxable |
| Commission on sale of DTH currency | No | Taxable |

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### References:

* Mega Exemption Notification No. 25/2012-ST dated 20.6.2012 (covers SIM card & recharge coupons only)
* Service Tax Laws pre-GST regime
* CBEC Circulars on telecommunication service tax

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If you want, I can help draft a formal legal opinion or assist with relevant service tax codes for compliance. Would you like that?

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