Crowe, who starred as a tobacco executive in 1999's The Insider, was filmed lighting up in the closing moments of an interview with the Nine Network's 60 Minutes programme in October 2000.
Part of the interview was replayed on the show the next week, following complaints from viewers about Crowe's smoking habit.
But the Australian Broadcasting Authority, which regulates the country's TV, radio and internet output, decided the footage was in breach of the Tobacco Advertisement Prohibition act, as the actor was clearly seen brandishing a packet of Marlboro cigarettes.
It said that showing the brand of cigarettes in the original footage was an "incidental accompaniment" allowed under the act.
But the regulator said the repeat broadcast "recklessly" constituted a tobacco advertisement.
"Crowe's celebrity and fame meant that members of the general public who saw the interview might seek to emulate him," a spokesperson added.
The country's Federal Court has ruled in the authority's favour, although no fine has been imposed upon the TV station.
The Nine Network, owned by Australia's richest man Kerry Packer, is now challenging the court's decision.
His lawyers have said it would have been impossible to broadcast the footage, meant to portray Crowe's behind-the-scenes image, without showing the smoking clip.
The court is expected to reach a verdict on Thursday.
Crowe is well known for his controversial behaviour.
Last month two men were cleared of attempting to blackmail the star with a surveillance video of him involved in a fight outside a nightclub.
Earlier this year he hit out at British TV company Initial Productions after his acceptance speech at the Bafta film awards was cut short on the show's TV broadcast.
Crowe began reciting poetry while picking up the Best Actor prize for A Beautiful Mind, but an edited version of the speech - minus the verse - was shown.