B. N. Srikrishna, C. J.

Both these Writ Petitions under Art.226 of the Constitution of India challenge the imposition of service tax under Finance Act of 1994, as amended by the Finance Act of 2001, on the taxable service provided by a photography studio or agency, in relation to photography, in any manner.

2. Service tax was introduced for the first time by the Finance Act, 1994 and levied on certain categories of services like stock brokers, general insurers and telephone services. It came to be extended to advertising agencies, courier agencies and pager services by the Finance Act of 1996. The service tax net was widened by adding twelve more services by the Finance Act, 1997. By the Finance Act, 1998, twelve more service were brought within the purview of service tax, namely, Architects, Interior Decorators, Management Consultants, Real Estate Agents, Practising Chartered Accountants, Practising Company Secretaries, Practising Cost Accountants, Security Agencies, Credit Rating Agencies, Market Research Agencies, Under Writers and Mechanised Slaughter Houses. The relevant definitions under the Finance Act are as under:

S.65(47): Photography. - "Photography includes st