Definition of Commercial (one of) - engaged in transporting passengers or goods for profit.
So interpreting the regs one cannot advertise for commercial ops without an AOC.
Can one advertise for non commercial op? Which is what this private op is. I.E. Joy Flight to XXX non revenue flight just help pilot pay costs of $XXX per person. Legal? Illiegal?
Its not so much about the regs it about who is interpresting the regs at the time, that is the point I am trying to make above.
Ah yes the old sell some fruit for a flight, if memory is correct Reg Ansett did this when he was having problems with the authorities way back when!