Kiran Raj

The Supreme Court of India Division Bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan, on Friday (January 16, 2026), held that the consideration paid by HT Media Limited (Hindustan Times Media Ltd.) to secure international speakers through overseas booking agencies for its annual Hindustan Times Leadership Summit does not attract Service Tax under the category of “Event Management Service”. The Court set aside the tribunal order that had upheld a service-tax demand of about ₹60.56 lakh on these payments. The dispute arose from the tax department’s position that arranging such speaker appearances—through agencies engaged to book speakers including Tony Blair, Al Gore and astronaut Jerry Linenger—amounted to a service connected with managing the event, making the organiser liable under the applicable charge mechanism.

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HT Media Limited organised the annual Hindustan Times Leadership Summit, for which it invited speakers from outside India and entered into contracts with overseas booking agencies to secure their participation.

The tax department issued show-cause notices under the Finance Act, 1994 proposing Service Tax on the fees paid for such speakers through the booking agencies, classifying the activity as “Event Management Service” under Section 65(105)(zu) read with Sections 65(40) and 65(41), and invoking the extended period. The notices were adjudicated by the Commissioner, who confirmed the demand with interest and penalty by applying Section 73; on appeal, the appellate tribunal set aside the extended-period invocation but sustained the demand for the normal period under the same taxable category.

The company’s case was that the agencies acted as lecture booking agents for the speakers, negotiating contracts and collecting appearance fees on the speakers’ behalf; it relied on confirmations from the agencies and on the TRU Circular dated 08.08.2002 describing the typical scope of an “event manager.”

The department disputed the agency characterisation, pointing to contractual terms describing the booking agent as an independent contractor, and contended that procuring speakers was integral to the Summit’s planning/presentation and therefore taxable under the event-management entry. The dispute period was October 2009 to March 2012, with the demand stated at ₹60,56,180, and the issue was examined in the context of the reverse charge mechanism under the Finance Act.

The Court observed that “the impugned levy of Service Tax can be sustained only if the service in question falls within the four corners of ‘event management’ by an ‘event manager’.”

After examining the contractual documents, the Court recorded that “a bare perusal of these agreements would indicate that they are in the nature of booking a particular speaker for the Summit.” It further noted that “the services rendered by such agents to the assessee were in the nature of booking the speakers for the event to be organized by the assessee.”

The Court stated that “such services cannot be equated with ‘event management service’ which has been statutorily defined to mean ‘any service provided in relation to planning, promotion, organizing or presentation of any arts, entertainment, business, sports, marriage or any other event’.” It clarified that “the contract of the assessee with the booking agents was not for ‘management of an event’ but for booking of the speaker.”

Rejecting the revenue’s emphasis on agency principles, the Court observed that “this is wholly irrelevant for the present controversy.” It recorded that “the issue is not whether the relationship between the speaker and the booking agent is that of ‘principal-agent’ or not.” The Court stated that “the issue is whether the contract constitutes ‘event management service’.”

Addressing the argument that the speakers constituted the event itself, the Court observed that “the presence of the speaker is essential for the event cannot be disputed.” However, it clarified that “whether the service of the speaker or the agent on behalf of the speaker can be considered to be ‘event management service’ is altogether a different issue.”

The Court recorded that “the speaker does not plan, promote, organize or present the event.” It further stated that “participation in the event cannot be considered as management of the event.” The Court concluded that “this precisely is the fundamental error committed by the revenue as well as by the Tribunal while imposing Service Tax on the service in question under the category of ‘event management service’.”

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On statutory interpretation, the Court observed that “the principle of strict interpretation of a taxing statute, particularly in the context of charging provisions, is well established.” It recorded that “if the case is not covered within the four corners of the provisions of the taxing statute, no tax can be imposed by inference or by analogy.”

The Court directed that “these appeals succeed and are hereby allowed. The impugned judgment and order passed by the Tribunal is hereby set aside.”

Advocates Representing the Parties

For the Appellant: Mr. Ashok Dhingra, Adv. Mr. Karan Bharihoke, AOR Ms. Sonia Gupta, Adv.
For the Respondent: Mr. V.C. Bharathi, Adv. Mr. Gurmeet Singh Makker, AOR Mr. S.K.singhania, Adv. Mr. P.V. Yogeshwaran, Adv. Mr. Annirudh Sharma II, Adv.

Case Title: HT Media Limited v. Principal Commissioner Delhi South Goods and Service Tax
Neutral Citation: 2026 INSC 66
Case Number: Civil Appeal Nos. 23525–23526 of 2017
Bench: Justice J.B. Pardiwala, Justice K.V. Viswanathan