A person rents hoardings to a advertisement agency(say first party transaction) who inturn put's the adverstisements of it's clients on the hoarding.
Is the first person transaction i.e., renting of hoarding to an agency, renting of immovable property services or advertisement service? The owner has no relation with the transactions between advertiser and it's clients. Owner just gets rent every month/year.
I am of the openion that since the essense of the transaction is not a contract of advertisement on behalf of the owner, it is renting of immovable property service and the advertisement agency is bound to pay service tax to the owner.
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