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2016 (7) TMI 559 - CESTAT BANGALORE

2016 (7) TMI 559 - CESTAT BANGALORE - TMI - Intellectual Property Service (IPR) - IPRs covered under Indian Law in force - import of services - taxability - extended period of limitation - appellants entered into License Agreement with foreign companies and obtained rights to use the technology for manufacture in consideration of which they had paid technical know-how fees and royalty charges - period from 01.01.2006 to 31.12.2006 - The appellants state that these foreign companies transferred l .....

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bject matter(s) of transfer of various documents/drawings, designs, softwares, catalogues, technical assistance/training documents/symbol numbering system etc., done under respective agreements which are on the record of these proceedings are not covered under the definition of 'Intellectual Property Right' as given in Section 65(55a) of Finance Act 1994 and consequently subject transfers of 'right to intellectual property', if any, covered by those transactions do not come within the definition .....

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intellectual property', if any, covered by those transactions do not come within the definition of 'Intellectual Property Service' given in Section 65(55b) of the Finance Act, 1994 and the service(s) if any, provided by the foreign companies by way of transfer of subject matter(s) under respective agreements to the appellants cannot be covered under the taxable service of 'Intellectual Property Service' as defined under Section 65(105)(zzr) of the Finance Act, 1994. - Demand set aside - Dec .....

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d the demand of ₹ 1,22,82,303/- (Rupees One Crore Twenty Two Lakhs Eighty Two Thousand Three Hundred and Three only) against the appellant under the category of Intellectual Property Service under Section 73 of the Finance Act along with interest under Section 75 of the Finance Act and has further imposed penalties under Section 76 of the Finance Act 1994. 1.1. The impugned order mentions the fact that the appellants entered into License Agreement with foreign companies and obtained righ .....

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al Property Service. 2. The appellants have been represented by learned advocate, Shri G. Shivadass, who has inter alia submitted as follows: 2.1. (a) M/s. ABB Ltd. (hereinafter referred to as the appellants) are engaged in the manufacture of various electrical goods such as Control and Relay Panel, Capacitors, Relays, Drives, DCS Systems, Air Circuit breakers, Contactors, Motors etc; and also providing services viz., erection, installation, commissioning of said equipment and machinery. (b) .....

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ts designed to operate at voltages upto and including 690V. (iv) M/s. ABB Technologies Ltd. License Agreement concerning the transfer of technology for standardized solutions for Advanced Power System Management. (v) M/s. ABB OY Drives, Finland Helsinki License Agreement concerning the production of ACS 550 and ACH 550 Frequency converters. (c) In terms of the above mentioned agreements, the Companies in question would provide to the appellants documents (etc.) related to general data relating t .....

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software by R & D Centre Global Supplier support which will have global certification - Under laboratories Complete set of manufacturing drawings Technical provisions for material, semi-finished product Supervision and inspection as well as additional technical documentation necessary for to enable licensee to manufacture product with quality similar to that of licensor manufactured. Bill of material Assembly drawing Pictures Specification of material and source Manufacturing documentation M .....

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exclusive property of the respective entities. Under the aforesaid agreement(s) the Companies transferred licensed use of their technical information, know-how and trade secrets which were not registered under any Indian law for time being in force. They did not license to the appellants any patent, copyright, design, or any other similar intellectual property rights. Certificates obtained from the Foreign Companies are enclosed. 2.2. Earlier also department issued a show-cause notice dated 22. .....

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isions under Section 84 of the Central Excise Act and issued show-cause notice dated 07.09.2007 for taxing the services under Intellectual Property Service and demanded service tax of ₹ 39,98,975/- (Rupees Thirty Nine Lakhs Ninety Eight Thousand Nine Hundred and Seventy Five only) along with interest and for imposition of penalties. Commissioner against the show-cause notice passed the Order-in-Original No. 31/2007 dated 10.04.2008 confirming the demand of service tax along with interest .....

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reign companies make available to the Appellants knowledge by means of data, experience, for the purpose of manufacture, sale and use of the Contract Products. This knowledge may be made available in written form, any other recorded form or in the form of personal experience. In the present case, Foreign Companies had supplied the Appellants technical know-how, which is a fact accepted in the Show Cause Notice itself. (ii) The Finance Act, 2004 w.e.f. 10.09.2004 inserted Intellectual Property S .....

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(b) permitting the use or enjoyment of, any intellectual property right; (105) taxable service means any service provided or to be provided,- (zzr) to any person, by the holder of intellectual property right, in relation to intellectual property service; (iv) While explaining the scope of service under the above insertion the Department has issued a clarification vide F. No. B2/8/2004 TRU dated 10.09.2004 which provides as under: 09. Intellectual property services (other than copyrights): 9.1 .....

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such laws as are applicable in India, IPRs covered under Indian law in force at present alone are chargeable to service tax and IPRs like integrated circuits or undisclosed information (not covered by Indian law) would not be covered under taxable services. 9.2 A permanent transfer of intellectual property right does not amount to rendering of service. On such transfer, the person selling these rights no longer remains a holder of intellectual property right so as to come under the purview of t .....

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ow how is the undisclosed information cited by the aforementioned departmental clarification dated 10.9.2004, as example of intellectual property right not covered by any Indian law. Therefore, grant of right to use Know how is not a service even under the taxable service of intellectual property service and thus not subject to service tax. (vi) The Appellant relies on the order of the Tribunal in the case of M/S Indian Farmers Fertilizers Co-operative Ltd. Vs. CCE, Bareilly (2007 (5) S.T.R. .....

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les its user to derive commercial benefit from it. Know-how as an intellectual property, would mean a proprietary series of practical, non-patented knowledge, derived from the owners experience and tests, which is secret, substantial, and identified. It is secret because it is not generally known or easily accessible. ... 14. As noted above, know-how as an intellectual property is sometimes also referred to a trade secret which enables its user to derive commercial benefit from it. A trade se .....

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-how gives perpetual monopoly in such secret information which does not expire over a period of time as is usual for the protection in form of validity period granted to patents and copyrights. Where trade secrets are recognized, the creator of property regarded as trade secret is entitled to regard some special knowledge as intellectual property. A trade secret is such sort of information, which is not generally known to the relevant portion of the public, that confers some sort of economic ben .....

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iance is placed on the following cases: (i) OEN India Limited v. CCE Cochin, 2008-TIOL-1589-CESTAT Bangalore (ii) CST, Faridabad v. G.E.C Avery Ltd. 2008 (10) STR 297 (Tri. - Del) (iii) CCE, Daman v. Supreme Treaves (P) Ltd. 2009-TIOL-179-CESTAT-AHM (iv) Toyota Motor Corp Japan v. CCE&ST, Bangalore 2007-TIOL-1865-CESTAT-BANG (v) Larsen and Tourbro Ltd. v. CST, Chennai 2008-TIOL-2357-CESTAT-MAD (ix)The Appellants have placed on record the certificates obtained from all its foreign collaborato .....

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ubmit that all the agreements specifically provide that the registration or non-registration of the intellectual properties given, if any, will not have any effect on the payment of royalty by the Appellants. Thus, it is evident that there was never ever an intention between the Appellants and the Foreign Companies to transfer any intellectual property under the Agreement. The Appellants are extracting clause 5 of the Agreement with ABB Stotz-Kontakt GmbH, which reads as follows: Clause 5 - Inte .....

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. [Emphasis supplied] (xii) It is submitted that similar clause is present in each and every agreement entered by the Appellants in the present case. Thus, without prejudice to the argument that no IPR which is protected under any Indian law for the time being in force has been transferred to the Appellants, since the agreement specifically provides that the consideration is having no nexus with any IPR transferred under the agreement the royalty payment made cannot be made liable to Service Tax .....

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ow how would be covered under Indian law, the Designs Act, 2000. (ii) The appellants in this regard submit that the above finding is erroneous as the Agreements for transfer of technical know how entered into between the appellants and the foreign collaborators contain certain designs which are subjected to protection under the Designs Law of the foreign country to which foreign collaborator belongs. (iii) It is submitted that designs rights are protected by the municipal laws of each country an .....

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signs under Indian law as per the requirements of the Indian Designs Act, 2000 and Design Rules, 2001. Therefore it is submitted that none of the designs transferred to the appellants as a part of technical know how are designs for the purpose of the Designs Act, 2000 and Designs Rules, 2001. The designs are merely Product Specifications to maintain the standards and quality control while manufacturing the goods by the appellants. Hence there is no transfer of Designs Rights from foreign ent .....

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definition of Intellectual Property Service, there is no attempt to examine and prove that the technical know-how is an Intellectual Property Right coming under service tax levy. (iii) There is plethora of case laws which lay down that in a case of taxation, the burden of proving the necessary ingredients prescribed by the taxing provision are satisfied, is entirely upon the taxing authority. The appellants place reliance on the following case laws: S.N. Uppar & Co. V. Commissioner of C.Ex. .....

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ertilizers and Chemicals, Travancore Ltd., 1986 (24) ELT 388 (Tribunal). Tata Export Ltd. V. Union of India and others, 1985 (22) ELT 732 (MP) Hevaecrumb Rubber (P) Ltd. V. Superintendent of Central Excise, 1983 (14) ELT 1685 (Ker.). Navin Chimmanlal Sutaria V. Union of India and others, 1981 (8) ELT 913 (Bom.). 3-D ENTIRE ISSUE IS ONE OF REVENUE NEUTRAL (i) In terms of Rule 9(1)(e) of the Cenvat Credit Rules, 2004 the person liable to pay service tax under Rule 2(1)(d)(iii),(iv) and (v) of the .....

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d the MODVAT credit availed were identical and therefore consequences of payment of excise duty after availing MODVAT credit was revenue neutral, therefore the appeal is dismissed leaving the question of law open. (iii) In this regard, the Appellants also rely on the following decisions:- Amco Batteries vs. CCE 2003 (153) ELT 7(SC) CCE, Mumbai Vs. Mahindra & Mahindra Ltd., 2005 (171) ELT 159 (SC) CCE, Mumbai Vs. Mahindra & Mahindra Ltd., 2005 (179) ELT 21 (SC) CCE vs. Naramada Chematur P .....

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view of the above submissions, the Appellants submit that no interest can be levied in terms of Section 75 of the Act. The Appellants further inter alia submit as follows: (a) The Appellants submit that Section 75 does not provide for payment of interest by a person liable to pay service tax under Section 66A which is a separate charging section. It refers to Section 68 only which is applicable for services rendered in India and not to Section 66A which is for services rendered outside India. (b .....

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04 (174) ELT 19 (Tri-LB) 4. The Revenue has been represented by learned AR, Shri Mohd Yusuf, who has reiterated the findings given in the impugned order dated 03.08.2007. Learned AR has cited the CESTAT, Chennais decision in the case of Suolificio Chennai Vs. CST, Chennai [2008 (11) S.T.R. 414 (Tri.-Chennai)] saying that transfer of trademarks and drawings, prima facie covered under Intellectual Property Service and therefore subject transactions are liable for service tax under the category o .....

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foreign companies is, covered under the taxable service of Intellectual Property Service? and if so whether it is liable to levy of service tax under Chapter 5 of the Finance Act 1994 and the Rules made thereunder? The subject show-cause notice dated 20.04.2007 inter alia says that appellants entered into an agreement with respective foreign companies and obtained rights to use the technology for manufacture/sale/marketing the goods on behalf of them and further states that the assessee receive .....

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Intellectual Property Rights as defined under Section 65(55b) of the Finance Act 1994 as amended (hereinafter called as the said Act) which reads as follows:- Intellectual Property Service means (a) transferring, whether permanently or otherwise; or (b) permitting the use or enjoyment of, any intellectual property right. Section 65(55a) defines Intellectual Property Right as any right to intangible property, namely, trade marks, designs, patents or any other similar intangible property, under .....

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pecifications of the said goods on a temporary basis and paid royalty as consideration which would squarely (fall) under the definition of Intellectual Property Services. 6.2. In respect of the issue mentioned above the appellants have made agreements with the foreign group companies for receiving various kinds of documents etc related to general data relating to Technology, Tools and jigs, Special machines and equipment, Quality Control and Quality Assurance to enable the appellants to manufact .....

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global certification - Under laboratories Complete set of manufacturing drawings Technical provisions for material, semi-finished product Supervision and inspection as well as additional technical documentation necessary for to enable licensee to manufacture product with quality similar to that of licensor manufactured. Bill of material Assembly drawing Pictures Specification of material and source Manufacturing documentation Manufacturing specifications Job instructions Time standards Drawings .....

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ration Nothing in this Agreement shall oblige either Party to apply for, take out, maintain or defend any intellectual property rights or trademarks in any country, nor does any Party assume any liability for the validity of intellectual property rights or trademarks. The rejection, expiry, abandonment or nullification of any Intellectual Property Right or Licensed Mark have no influence on amount of and obligation to pay the remuneration. 5.2. Rights of Third Parties Neither Party shall be held .....

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roducts and corresponding documentation are marked with the reference S 270 as applicable, and/or with an appropriate reference to the Intellectual Property Rights licensed under this agreement. The Licensee shall notify the Licensor of any infringement of the Intellectual Property Rights which comes to its knowledge. 6.4. Further we reproduce from the letter which has been written to the appellants on 02.07.2008 on behalf of General Manager of Foreign Group Company namely M/s. ABB n.v. Power Qu .....

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are not registered under any Indian law for time being in force. This letter further says that the technology transferred under this agreement is exclusive property of ABB, Belgium. Similar letters in respect of the agreements entered into with other foreign group companies which are subject matter of this case have also been filed by the appellants. 6.4.1. In order to make above things more clear and contextually more meaningful, we are reproducing above referred letter herein below: 6.5. Befor .....

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1 Intellectual Property Right as defined under Section 65(55a) of Finance Act 1994 is as follows: 1[(55a) intellectual property right means any right to intangible property, namely, trade marks, designs, patents or any other similar intangible property, under any law for the time being in force, but does not include copyright; Which has been inserted by Finance Act 2004 dated 10.09.2004 (made effective from 10.09.2004) Intellectual Property Service as defined under Section 65(55b) is as follows: .....

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.2. From the above provisions concerning Intellectual Property Right, Intellectual Property Service, and Taxable Service of Intellectual Property Right, we find that for any services to be covered under the taxable service concerning intellectual property right, the following ingredients need to be present: (i) the said service need to have the element of the intellectual property right and covered as such by the definition of intellectual property right given in the Section 65(55a) of the F .....

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companies are transferring any intellectual property right to the appellants, which could be covered under the definition of intellectual property right as given under Section 65(55a) of Finance Act, 1994. This definition of Section 65 (55a) says that it is any right to intangible property namely, (a) trade marks, (b) designs, (c) patents or (d) any other similar intangible property, under any law for the time being in force, but does not include copyright. 6.6.1. We find that foreign group com .....

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ements between the foreign group company and the appellant can be termed as right to intangible property which is either a trademark or design(s) or patent(s) or any other similar intangible property recognized as such under any existing Indian law (and when it is not a copyright under Indian Copyright Law); and then only such a right would be covered under the definition of Intellectual Property Right as defined in Section 65(55a) of the Finance Act 1994. From the documents on record which are .....

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ture various contracted products and the right to use or otherwise dispose of such products which is evident from the Clause 2.1 of the respective agreement(s). The contents of the Clause 2.1 of the License Agreement between ABB Sace S.p.A. Milano-Italy (Licensor) and the appellants (Licensee), are being reproduced below for making the scope of the subject agreement(s) more clear:- CLAUSE 2 - LICENCES 2.1. Scope Licensor grants Licensee under Information and Intellectual Property Rights (if any) .....

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ion. 6.6.3. Important point here is whatever is under transfer by the foreign companies under the respective licenses, - is the said subject matter a right to an intangible property and is the said intangible property is a trademark or design or a patent or any other similar intangible property under an Indian law? Here we do not find any evidence to categorically hold that the technical information or technical know-how or the designs or patents or the documents etc which are the said subject m .....

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004. In respect of Intellectual Property Service the said CBEC Circular in its para 9 says as below: 9.Intellectual property services (other than copyrights): 9.1 Intellectual property emerges from application of intellect, which may be in the form of an invention, design, product, process, technology, book, goodwill etc. In India, legislations are made in respect of certain Intellectual Property Rights (i.e. IPRs) such as patents, copyrights, trademarks and designs. The definition of taxable se .....

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s not amount to rendering of service. On such transfer, the person selling these rights no longer remains a holder of intellectual property right so as to come under the purview of taxable service. Thus, there would not be any service tax on permanent transfer of IPRs. 9.3 In case a transfer or use of an IPR attracts cess under Section 3 of the Research and Development Cess Act, 1986, the cess amount so paid would be deductible from the total service tax payable (refer Notification No. 17/2004- .....

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as not been able to prove in any manner that right to any of the intangible properties (by whatever name they call the same i.e. either documents or designs, instructions, catalogues, drawings, product software, testing specification, symbol numbering system, technical know-how, pictures and so on) is covered as IPR(s) under any of the relevant Indian law. In case of undisclosed information this CBEC circular itself says that an Indian law does not cover such undisclosed information. In other wo .....

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missions that by way of these agreements the technologies are being transferred by the foreign companies which were developed by them and are the exclusive property of the respective companies. The appellants state that these foreign companies transferred licensed use of their technical information, know-how and trade secrets which are not registered under any Indian law for time being in force. The appellants further state that foreign companies did not grant license to them any patent, copyrig .....

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ure do not help the case of the Revenue when the subject matter(s) of respective agreement(s) do not fulfill the criteria and conditions of the definition of Intellectual Property Right of Section 65(55a) of the Finance Act, 1994. 7.1. Revenue has also cited the case laws in the case of Indian Farmers Fertilizer Co-op. Ltd. Vs. CCE (supra) and Suolificio Chennai Vs. CST, Chennai (supra). We find that CESTAT, Delhi in the case of Indian Farmers Fertilizer Co-op. Ltd.(supra) mainly discussed the C .....

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e has also referred to CESTAT, Chennai s decision in the case of Suolificio Chennai (supra) where it has been held that transfer of trademarks and drawings, prima facie covered under Intellectual Property Service. Again we do not find any assistance to the Revenue from this decision because firstly it is on the subject of Consulting Engineer Service and secondly we do find that the subject matter(s) of the agreement(s) between the foreign companies and the appellants in the present case are not .....

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of said subject matters/documents etc. under corresponding taxable service namely Intellectual Property Service which has been further defined in Section 65(55b) of the Finance Act, 1994. 7.2. Further we refer to CESTAT, Mumbais decision in the case of Rochem Seperation Systems (supra). CESTAT, Mumbai has inter alia observed in the paras of the said decision as under: 8... However, the Commissioner failed to analyze the Agreements in detail and came to a hasty conclusion that the entire amount .....

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l Property Right service. 7.2.1. Rochem Seperation Systems (supra) is the case that though discusses the issue of Intellectual Property Right it concluded there that the demand is time-barred, we are deciding the matter only on the basis of limitation. Further we refer to CESTAT, Mumbai s decision in case of Tata Consultancy Services Ltd. (supra), where it held that intellectual property right not covered by Indian laws would not be covered under the taxable service in the category of IPR servic .....

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property right. And Intellectual Property Right as defined under Section 65 (55a) means any right to intangible property, namely, trade marks, designs, patents or any other similar intangible property, under any law for the time being in force, but does not include copyright. 4.1 Short question to be decided is whether the transfer of technical 'know how' received by the appellant is a service which may be categorized under "Intellectual Property Right Services". We find that .....

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e Trade Mark which is a right provided under "Trade Marks Act". Similarly the right mentioned as 'design' in the definition is a right under the "Design Act". Therefore we find that the technical know-how received by the appellant and the royalty payment made by the appellant to Unisys is nowhere established to result from the use of any Intellectual Property Right. 4.2 We may further go on to add that the Intellectual Property Right should be a right under the Indian .....

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al Property Rights (i.e.IPRs) such as patents, copyrights, trademarks and designs. The definition of taxable service includes only such IPRs (except copyright) that are prescribed under law for the time being in force. As the phrase ''law for the time being in force'' implies such laws as are applicable in India, IPRs covered under Indian law in force at present alone are chargeable to service tax and IPRs like integrated circuits or undisclosed information (not covered by Indian .....

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r to CESTAT, Mumbai s decision in the case of Thermax Ltd. (supra). CESTAT, Mumbai in the said decision has observed that the subject transaction has to satisfy the requirement of Section 65(55b) of the Finance Act, 1994 so as to cover the same under the service concerning Intellectual Property Right. We reproduce para 5.5 of the said decision which says that for any transaction to be covered under IPR services has to be first covered under the category of an IPR under an Indian law. CESTAT, Mum .....

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