K.K. Usha, President - The appellant-assessees who are held liable to pay service tax challenge the orders passed by the Commissioner of Central Excise (Appeals) Mumbai dated 18-11-2002 rejecting their appeals against the orders of adjudication. Since both the appellants raised a common contention that their activities cannot be termed as ‘taxable service’ as defined under section 65(72), as it stood during the relevant period, the appeals are disposed of by a common order. According to them they are not providing any service to a client as a broadcasting agency or organization in relation to broadcasting in India. Therefore, the demand of service tax is not sustainable.

2. M/s. Zee Telefilms Ltd., appellant in ST/4/2003 are representatives of M/s. Asia Today Ltd. (ATL) and M/s. Expand Fast Holdings Ltd. (EXPAND), Mauritius in India for selling time slot for advertisement and for obtaining sponsors for serials, programmes, events, etc. which would be played out by ATL/EXPAND in the various channels like ZEE TV, ZEE Cinema, Music Asia. Appellant in ST/5/2003 are representative of M/s. Satellite Television Asian Region Limited (STAR) Hong Kong in India for selling time slot fo