HT Media Limited v. Principal Commissioner, Delhi South GST

 Case Details

Citation: 2026 INSC 66
Decided on: 16 January 2026
Case Title: HT Media Limited v. Principal Commissioner, Delhi South GST
Court: Supreme Court of India
Bench: J.B. Pardiwala J., K.V. Viswanathan J.

 

Background

HT Media Ltd. organised the annual Hindustan Times Leadership Summit and engaged foreign booking agencies (Washington Speakers Bureau, Harry Walker Agency) to secure participation of eminent speakers. The Revenue sought to levy Service Tax under the “Event Management Service” category on the fees paid to speakers through booking agents for the period October 2009–March 2012. While the CESTAT rejected extended limitation, it upheld the demand for the normal period.

 

Issues Framed

1. Whether booking agents securing speakers for an event provide a taxable “event management service” under ss. 65(40), 65(41) r/w s. 65(105)(zu) Finance Act, 1994.
2. Whether Service Tax can be levied by treating speaker-booking services as event management under the reverse charge mechanism.
 

Court’s Reasoning

1. Scope of “event management service” under the Finance Act

• Event management is statutorily defined as services relating to planning, promotion, organising or presentation of an event, including consultation .
• The TRU Circular dated 08.08.2002 clarifies that an event manager manages venues, logistics, publicity, stage, artists, security, etc., and executes the event as a whole.

2. Nature of services rendered by booking agents

• The contracts showed that booking agents merely facilitated the availability and appearance of speakers, fixed schedules, fees, and logistics relating to the speakers alone.
• They neither planned nor organised the Summit, nor managed the venue, publicity, or execution of the event.
• Participation of a speaker, however important, is not synonymous with management of the event; presence ≠ event management.

3. Irrelevance of principal–agent debate

• Whether booking agents acted as agents of the speakers or independent contractors was held irrelevant. The decisive question is classification of the service, not the agency relationship.

4. Strict interpretation of taxing statutes

• A taxing entry must be applied strictly; tax cannot be imposed by inference or by stretching statutory language (Shiv Steels, relied upon).
• Even applying the common parlance test, booking a speaker is not understood as event management.

5. Classification under other taxable heads

• The Court rejected the appellant’s alternative reliance on International Merchandising Company LLC, holding that although classification must be singular, the facts there were distinguishable. Nevertheless, the Revenue could not tax the service as event management.
 

Decision / Disposition

Appeals allowed. The CESTAT’s order upholding Service Tax demand under “Event Management Service” was set aside. No Service Tax was payable on fees paid for booking speakers under the impugned category.

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