Allowing use of Brand name for sale of that Brands Product does not Liable to Service tax Under Intellectual property

Sale of the goods through an agent and for sale of Man­u­fac­tur­er prod­ucts use of their Brand Name so as to ensure max­i­mum pro­duc­tion and sale does not entail use of Intel­lec­tu­al prop­er­ty & liable to ser­vice tax.

The Mum­bai CESTAT in the case of Y.M Krish­na S.S.K Ltd. v. Com­mis­sion­er of Cen­tral Excise, Pune-II, 2014 (36) 838 (Tri. – Mum­bai) has held that the no Ser­vice tax is payable under Intel­lec­tu­al Prop­er­ty Ser­vice in respect of sell­ing agency agree­ment entered into between the Appel­lant and M/s Tal­re­ja Trade (HUF) for allow­ing the HUF to use the brand name ‘Pahili Dhar’ in sell­ing the appellant’s products.

The Appel­lant is engaged in man­u­fac­tur­ing coun­try liquor (out of their raw material/packing mate­r­i­al) under brand name “Pahili Dhar”. The Appel­lant had entered into sell­ing agency agree­ment with HUF for sale of coun­try liquor of their brand name where­in, the pack­ing mate­r­i­al was to be sup­plied by HUF and after­wards HUF was sup­posed to col­lect the sale pro­ceeds from the cus­tomers and after deduct­ing the price of the pack­ing mate­r­i­al, essence, etc., the remain­ing sale pro­ceeds were to be hand­ed over by him to the appellant.

The Depart­ment issued SCN alleg­ing that the Appel­lant have allowed HUF to use its brand name for mar­ket­ing coun­try liquor and this activ­i­ty falls under the cat­e­go­ry of Intel­lec­tu­al Prop­er­ty Services.

The Hon’ble CESTAT in the present case has held that the trans­ac­tion is pure­ly of sale of the goods through an agent and not a trans­ac­tion of allow­ing anoth­er to use Intel­lec­tu­al prop­er­ty. Fur­ther the agree­ment clear­ly men­tions that M/s Tal­re­ja Trade will not be enti­tled to the use of the brand name in any way. The agree­ment between the Appel­lant and M/s Tal­re­ja Trade was for allow­ing to use the brand name for sale of appellant’s prod­ucts so as to ensure max­i­mum pro­duc­tion and sale of Coun­try Liquor. The min­i­mum guar­an­tee of prof­it per month giv­en or assured by the agent to the Appel­lant have been mis­un­der­stood as Roy­al­ty which was not the fact.

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