JUDGMENT :

G.S. Kulkarni, J.

These four appeals arise from a common order dated 10th December 2018 passed by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Mumbai. By the orders as impugned in each of the appeals, the Tribunal has rejected the appellant’s appeals thereby confirming the Order-in-Original passed by the Assessing Officer. By the orders passed by the Assessing Officer, the demand for payment of service tax against the petitioner was confirmed. The service tax was sought to be levied on the services subject matter of the Agreement dated 21st January 2008 and 25th March 2009 (agreement in supersession of the earlier agreement) whereunder, the appellant had awarded media rights to one MSM Satellite (Singapore) Pte. Ltd. and World Sport Group (India) Pvt. Ltd. which were sought to be taxed by levy of service tax.

2. The appellant was issued show cause notices for the relevant periods being F.Y. 2007-08, F.Y. 2008-09, F.Y. 2010-11 and F.Y. 2011-12, classifying the assessee as a ‘Franchisee’ within the meaning of Section 65 (47) of Chapter V of the Finance Act, 1994 in relation to services rendered by it to MSM Satelite (Singapore) which were in respect of tel