Taxablity of comission recived on activation of dth


This query is : Resolved 

(Querist)
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

15 June 2013 Both are taxable services.

KUMAR (Querist)
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

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 (Querist)
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 (Querist)
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

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):

---

### 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.

---

### 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 |

---

### 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

---

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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