TMI Blog2019 (9) TMI 1141X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act read with Rule 5 of the 2006 Rules - HELD THAT:- The franchisee had to expend not less than 5% of the gross sales in a particular year towards the advertisement of its Restaurant. The amount was not required to be deposited in any fund of the franchisor for advertisement or promotion of the franchisor - What further transpires from the agreement is that there is no obligation cast upon the franchisee to incur any expenditure on advertising the brand name, service marks and trademarks of the franchisor. Any indirect result, because of advertisement cannot, therefore, be called an extra consideration in terms of section 67 of the Act. Unless an amount is charged by the service provider to the service recipient, it does not enter into an equation for determining the value on which Service Tax is payable. The order has grossly erred in interpreting the franchise agreement, thereby, including the cost of advertisement in the franchise fee received by the Appellant. The amount incurred by the franchisees towards advertisement expenses, cannot, therefore, be said to be consideration paid by the franchisee to the Appellant, as it is the franchisee themselves who are benefittin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e forward charge and reverse charge cannot be equated for the charge of interest as these are governed by different set of Rules - Demand of interest do not sustain. Extended period of limitation - HELD THAT:- The demand made in Issue No. 1, 2 and 4 has been set aside - With regard to Issue no. 3, the matter has been remitted to the Principal Commissioner to decide it afresh - Thus, it is not necessary to examine the issue relating to limitation, at this stage. Appeal allowed in part in favor of Assessee and part matter on remand. - Service Tax Appeal No. 50218 of 2016 - FINAL ORDER NO. 51264/2019 - Dated:- 25-9-2019 - MR. DILIP GUPTA, PRESIDENT AND MR. C.L. MAHAR, MEMBER (TECHNICAL) Shri S. Thirumalai, Advocate, for the Appellant Shri Vivek Pandey, Authorised Representative of the respondent ORDER This appeal seeks to assail the order dated 31 October, 2015 passed by the Principal Commissioner of Service Tax, New Delhi [Principal Commissioner ] on the three Show Cause Notices dated 17 August, 2013, 22 May, 2014 and 20 April, 2015 covering the period from April 2007 to March, 2014. The demand of service tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2014 and 20 April, 2015 covering financial year 2012-13 and financial year 2013-14, respectively were issued. The issues raised in the said Show Cause Notices that arise for consideration in this Appeal are as follows: a) Non-payment of service tax on advertisement expenses incurred by the local franchisees on behalf of the Appellant. b) Short payment of service tax due to wrong utilisation of cenvat credit. c) Non-payment of service tax on management consultancy services by wrongly claiming the same as export service . d) Interest on late payment of service tax on franchisee fees to McDonald s USA. 6. Details of these four issues covered by the three Show Cause Notices are tabulated below: Issue SCN 1 SCN 2 SCN 3 2007- 08 2008 -09 2009- 10 2010- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... there was short payment of service tax due to wrong utilisation of Cenvat Credit, non-payment of service tax on Management Consultancy Service by wrongly claiming it as export, and payment of interest on late payment of franchisee fees to McDonald s, USA. 8. The Appellant filed detailed replies dated 10 July, 2013, 4 July, 2014 and 18 May, 2015 to the three Show Cause Notices. 9. An Order dated 31 October, 2015 was passed by Principal Commissioner rejecting the contentions of Appellants. The demand of ₹ 43,33,31,760/- with interest and penalty of ₹ 1,13,86,747/- and ₹ 43,33,61,756/- respectively was confirmed. The Principal Commissioner relied upon the provisions of the Indian Contract Act, 1872 and concluded that through a contractual obligation, the Appellant was getting an extra consideration in the form of contribution towards advertisement from the franchisee for promotion of its own brand and not that of the franchisor. This extra consideration paid by the franchisee to the franchisor (Appellant) formed part of the value of taxable service of the franchisor. As regards receipt of export proceeds, the impugned order s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... develop, in agreed locations in India, restaurants in accordance with the terms and conditions of the license (the Restaurants ). C. McDonald s is willing to grant License such a nonexclusive license subject to the terms and conditions hereinafter stated. D. McDonald s and Licensee agree to enter into nonexclusive license agreement ( License ) on the terms and conditions hereinafter contained to carry out the foregoing. THEREFORE, in consideration of the privilege of conducting a restaurant business under this License, and the mutual obligations contained herein, the parties agree as follows: ................................ 2. License Grant and Term Licensor grants to Licensee for the following stated terms the non-exclusive right, license and privilege. ( License ): (a) to adopt and use the McDonald s System in Restaurants to be construed at locations to be mutually agreed upon by the parties hereto in India in accordance with the terms and conditions of this Agreement, and (b) to advertise to the public that it is a licensee of Licensor, and (c) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion, a company organized under the laws of the State of Delaware, United States of America ( McDonald s ) has developed and operates a restaurants system ( McDonald s System ). The McDonald s System includes proprietary rights in certain valuable trade names, service marks and trademarks, including the trade names McDonald s , McDonald s Hamburger and McDonald s Family Restaurants , designs and color schemes for restaurant buildings, signs, equipment layouts, formulas and specification for certain food products, methods of inventory and operation control, bookkeeping and accounting, and manuals covering business practices and policies. The McDonald s System is operated and is advertised widely within the United States of America and in certain other countries. McDonald s India Private Limited is a wholly owned subsidiary of McDonald s Corporation and McDonald s India Private Limited holds fifty (50) per cent of the capital of Connaught Plaza Restaurants Private Limited. McDonald s has authorised Franchisor to grant franchisee to operate McDonald s restaurants using the McDonald s System in India. Franchisee desires t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld s, Franchisor will only grant franchises to those companies that have a Managing Director who will live in the locality of the McDonald s restaurant and who will devote his full time and best efforts to the McDonald s business. Franchisee represents, warrants and agrees that he actually owns the complete equity interest in this Agreement and the profit from the operation of the Restaurant (defined below), and that it shall maintain such interest during the term of this Agreement except only as otherwise permitted pursuant to the terms and conditions hereof. Franchisee agrees to furnish Franchisor with such evidence as Franchisor may request, from time to time, for the purpose of assuring Franchisor that Franchisee s interest remains as represented herein. 2. FRANCHISE GRANT AND TERM (a) Franchisor grants to Franchisee for the following stated term the right, license, and privilege: (i) To adopt and use the McDonald s System in the restaurants constructed or to be constructed at E-31 and E-32, South Extension, Part II, New Delhi, India ( the Restaurant ) and at that location only, and (ii) To advertise to the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... romotion to the general public. 8. ROYALTY (a) Franchisee shall pay to Franchisor as a royalty five percent (5%) of the Gross Sales from the operation of the Restaurant during the term hereof. The royalty specified herein shall be calculated and shall be paid by Franchisee to Franchisor within five (5) working days after the end of each month. 9. FRANCHISE FEE. Franchisee shall pay to Franchisor a Franchise Fee for the right to operate the Restaurant in accordance with this Agreement in the amount of the Indian Rupee equivalent of twenty-two thousand five hundred United States Dollars (U.S.$ 22.500.00) . Franchisor reserves the right, in case construction of the Restaurant should be abandoned, the lease assigned, or other interest in the premises be relinquished, to terminate this Agreement upon reimbursement to Franchisee of the Franchise Fee. 12. COMPLANCE WITH ENTIRE SYSTEM . Franchisee and Joint Venture Partner acknowledge that every component of the McDonald s System is important to Franchisor and to the operation of the Restaurant as a McDonald s restaurant, including a designated menu of food ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Restaurant in Clause 2(a)(i) which uses capital R as against use of the said expression in other parts of the agreement with small ( r ), it is clear that the intention of the parties was that the advertising required was to be of the Restaurant and not the trade names, service marks and trademarks of the franchisor. The fact that advertising is only with respect to the Restaurant (with capital R ) is also evidenced by the advertising pull outs and the invoices of the advertisement agencies which are in the name of the Restaurant and are part of the Appeal paper book; (ii) While fulfilling the condition of the franchise agreement with respect to Clause 5 of the agreement by way of advertising the Restaurant, the trade names, service marks and trademarks of the franchisor may also appear in such advertisement, but this does not provide any extra consideration to the Appellant; (iii) The only condition of the franchise agreement is to require advertisement of the Restaurant and nothing else. Therefore, there is no legal obligation on the part of the franchisee to include the trade names, service marks and trademarks of the franchisor. Such ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt was affirmed by the Supreme Court in Union of India vs Intercontinental Consultants and Technocrats [2018 (10) G.S.T.L. 401 (S.C.)]. In such circumstances, the demand on the basis of the aforesaid Rule is unsustainable; (viii) The show cause notice refers to Rule 5(1) of the 2006 Rules and, therefore, no other Rule could have been relied upon to sustain the Order, as was observed by the Supreme Court in Commissioner of Central Excise, Bhubaneswar Vs. M/s. Champdany Industries Ltd.[ 2009 (241) E.L.T. 481 (S.C.)]; and (ix) Even otherwise, when a detailed procedure has been prescribed in paragraphs 4.1.5 and 4.1.6 of the Board Circular dated 19 April, 2006 for determination of the value when consideration received is not in terms of money, the Principal Commissioner could not have resorted to best judgment under Section 72 of the Act to include the entire expenses incurred by the franchisees. 16. Learned Authorised Representative of the Department however submitted: (i) The first part of Clause 5 of the Agreement provides that the franchisee shall use only advertising and promotional material and programmes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the McDonald s brand trade names, service marks or trademarks. There is no obligation on the part of the franchisee under the agreement to include the trade names, service marks and trademarks of the franchisor. Thus, such an un-enforceable condition with respect to the trade names, service marks and trademarks, according to the Appellant, cannot provide any additional consideration to the franchisor over and above the royalty payment as per Clause 8 of the agreement, on which service has been paid by the Appellant. 18. The Principal Commissioner, however, concluded that through the contractual obligation the Appellant was getting an extra consideration from the franchisee for promotion of its own brand in the form of contribution towards advertisement, which consideration would form part of the value of taxable service of the franchisor. The Principal Commissioner went by what consideration meant in Explanation (a) to Section 67 of the Act and concluded that the consideration could be in the form of cash, goods or services and non monetary consideration is determined under the 2006 Rules. Thus, since the franchisee, apart from remitting franchisee fees and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at McDonald s, USA has authorised the franchisor (the Appellant) to grant franchisees to operate McDonald s restaurants using the McDonald s System in India and the fact that the franchisee (Connaught Plaza) desires to acquire the right to adopt and use the McDonald s System in a restaurant at a location specified in the agreement. 20. Clause 1 of the agreement describes the McDonald s System as a comprehensive restaurant system for the retailing of a limited menu of uniform and quality food products, emphasizing prompt and courteous service in a clean, wholesome atmosphere which is intended to be attractive to children and families. Compliance by the franchisee with the aforesaid standards and policies in conjunction with the McDonald s trademarks and service marks provides the basis for the valuable goodwill and wide family acceptance of the McDonald s System. 21. Clause 2 of the agreement deals with Franchise Grant and Terms under which the franchisor has granted to the franchisee the right to adopt and use the McDonald s System in the Restaurant at South Extension Part-II, New Delhi and the right to advertise to the public that it is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ald s with no reference to any other names or entities. It also provides that the name of the franchise shall appear in the heading of receipts and in the headed paper and business cards used by the franchisee. Clause 16 of the agreement emphasises that the franchisee is and shall remain an independent contractor responsible for all obligations and liabilities 24. It would be appropriate at this stage to analyse the charge against the Appellant in the show cause notice. 25. The show cause notice alleges that since the franchisee has to expend during each calendar year an amount which is not less than 5 per cent of the gross sale for advertising and promotion of the restaurant system owned by Mcdonald s Corporation through the contractual obligation, the franchisor gets an extra consideration towards the advertisement from the franchisee for promotion of its own brand, instead of the franchisee, which amount will form part of the value of taxable service of the franchisor in terms of Section 67 of the Act read with Rule 5 of the 2006 Rules. The relevant portion of the show cause notice on this aspect and it is as follows: 1.7 Fro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the franchisee shall expend during each calendar year for advertisement and promotion of the Restaurant to the general public an amount which is not less than 5% of the gross sale for such year. Thus, what amount has to be spent by the franchisee is for the advertisement and promotion of either the Connaught Plaza Restaurant or the Hardcastle Restaurant and not for advertisement and promotion of the restaurant system owned by McDonald s, USA. 28. The same mistake has crept in the order of the Principal Commissioner since the said distinction between a restaurant and a Restaurant has not been appreciated. It is for this reason that a finding has been recorded by the Principal Commissioner that the Appellant was getting an extra consideration in the form of contribution towards advertisement from the franchisee. 29. As the very basis for recording the finding is based on a misreading of Clause 5 of the agreement, the finding recorded by the Principal Commissioner that the Appellant was getting an extra consideration in the form of contribution towards advertisement from the franchisee, is erroneous. 30. Learned Author ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it does not enter into an equation for determining the value on which Service Tax is payable. 34. A Larger Bench of the Tribunal in Bhayana Builders (P) Ltd. vs Commissioner of Service Tax [2013 (32) S.T.R. 49 (Tri. - LB)] observed that implicit in the legal architecture is the concept that any consideration whether monetary or otherwise, should have flown or should flow from the service recipient to the service provider and should accrue to the benefit of the latter. In the said decision, the Larger Bench made reference to the concept of consideration , as has been expounded in the decision pertaining to Australian GST Rules, wherein a categorical distinction has been made between conditions to a contract and consideration . It is prescribed under the said GST Rules that certain conditions to the contract cannot be seen in the light of consideration for the contract and the fact that the service recipient has to fulfil such conditions under the contract cannot form part of the value of the taxable services that are provided. The impugned order, however, enhances the value of taxable services by adding expenses of advertisement incurred by the franc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which value is sought to be determined. 36. The aforesaid view was reiterated by the Supreme Court in Intercontinental Consultants, wherein it was observed: 23. Obviously, this Section refers to service tax, i.e., in respect of those services which are taxable and specifically referred to in various sub-clauses of Section 65. Further, it also specifically mentions that the service tax will be @ 12% of the value of taxable services . Thus, service tax is reference to the value of service. As a necessary corollary, it is the value of the services which are actually rendered, the value whereof is to be ascertained for the purpose of calculating the service tax payable thereupon. 24. In this hue, the expression such occurring in Section 67 of the Act assumes importance. In other words, valuation of taxable services for charging service tax, the authorities are to find what is the gross amount charged for providing such taxable services. As a fortiori, any other amount which is calculated not for providing such taxable service cannot a part of that valuation as that amount is not calculated for providing such taxable service . Tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bligations under the franchise agreement, the franchisees have to undertake and the franchisor has to ensure that, the franchisees do so, advertising/promotion activities for the products of the franchisees that were local and specific to their business. The advertisement was for the promotion of the restaurants operated by the local franchisees and not for the promotion of the McDonald s brand. The clause in the agreement was to lay down certain benchmarks to ensure uniformity of operations and level playing field for all the local franchisees. [emphasis supplied] 39. This contention was not accepted by the Principal Commissioner and the finding is : The agreement entered with the franchisees were inter alia, as under Franchise Grant and Term : a. Franchisor grants to Franchisee for the following stated term the right, license, and privilege : (i) to adopt and use the McDonald s system in the restaurant constructed or to be constructed at E-31 and E-32, South Extension, Part-II, New Delhi, India ( the Restaurant ) and at that location only, and (ii) to advertise to th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terpreted. Clause 5 provides that in order to enable the franchisor to protect and preserve its worldwide range as a friendly, clean, wholesome, quick service restaurant suitable at all time for families, the franchisee shall only use the promotional materials and programs provided by the franchisor or approved in advance by the franchisor. The advertisement cannot be said to be for the benefit of any restaurant run by the Appellant because the Appellant does not run any restaurant. Any advertisement by the franchisee would enure to its own benefit since the advertisement would result in increase in the number of customers coming to the Restaurant. Merely because the agreement requires the franchisee to use only advertising and promotion materials and programs provided by the franchisor or approved in advance by the franchisor would not mean that the advertisement is for the benefit of the franchisor. As the first part of clause 5 of the agreement indicates, the reason why only such promotion materials and programs as provided by the franchiser are required to be used by the franchisee for advertisement is to protect and preserve the worldwide image of the franchisor as a friendly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rant has to operate as a McDonald s restaurant and thus the advertisement and promotion has to be of the McDonald s system only. The first paragraph of Clause 5 of the agreement also provides that the franchisee shall use only advertising and promotional materials provided by the franchisor. Thus, Clause 12 and the first paragraph of Clause 5 of the agreement dominate the second paragraph of Clause 5 of the agreement and there is no separate identity of the franchisee or the Restaurant. In this connection, reliance has been placed upon the decision of the Delhi High Court in Delhi International Airport. 45. It is not possible to accept the contention of the learned Authorised Representative of the Department. Clause 12 and Clause 5 of the agreement are very clear. The first paragraph of Clause 5 of the agreement emphasises why it would be necessary for the franchisee to use only the promotion materials and programmes provided by the franchisor for the advertisement. The second part of paragraph 5 of the agreement requires the franchisee to expend during each calendar year for advertising and promotion of the Restaurant to the general public an amount whi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the infirmity of neither being supported with the help of law and or facts for the purpose of the said allegations in the notice. 48. This contention was also not accepted by the Principal Commissioner and the finding is : The Show Cause Notice has termed expenses incurred on advertisement as an extra consideration by virtue of contract on record. Consideration means everything received or recoverable in return for a provision of service which includes monetary payment and also consideration of non-monetary nature or deferred consideration as well as recharges between establishments located in a non-taxable territory on one hand and taxable territory on the other hand. Non-monetary consideration essentially means compensation in kind. The non-monetary consideration also needs to be valued for determining the tax payable on the taxable service since service tax is levied on the value of consideration received which includes both monetary consideration and money value of non-monetary consideration. The value of non-monetary consideration is determined as per section of the Act and the Service Tax (Determination of Value) Rules, 2006. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... res the provisions of section 66 and 67 of the Act. The Delhi High Court accepted the said contention and declared Rule 5 to be ultra vires the provisions of section 66 and 67 of the Act. The High Court noted that both the amended and the un-amended section 67 authorized the determination of value of taxable services for the purpose of charging Service Tax under section 66 as the gross amount charged by the service provider for such services provided or to be provided by him in a case where consideration for such service is money. The High Court placed emphasis on the words for such service and took the view that the charge of Service Tax under section 66 has to be on the value of taxable service i.e. the value of service rendered by the assessee and the quantification of the value of service can, therefore, never exceed the gross amount charged by the service provider for the service provided by him. On that analogy, the High Court opined that the scope of Rule 5 goes beyond the scope of section 67 which was impermissible as rules could be framed only for carrying out the provisions of Chapter 5 of the Act. In taking this view, the High Court observed that the expenditure or cos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bservations of the Principal Commissioner on this issue are as follows : 1. As regards the issue related to allegation of Short payment of Service Tax due to wrong utilization of Cenvat Credit , I find that the department s case basically rest on the premise that the Noticee availed and utilized CENVAT credit of service tax paid by them for import of franchisee service under reverse charge mechanism under section 66A of Finance Act, 1994. CENVAT credit of service tax paid on import of service was allowed subject to the condition that the service should fall within the definition of input service given under sub rule 2(1) of CENVAT Credit Rules, 2004. Franchisee service was not an input service used for providing Management Consultancy services inasmuch as the franchisee service imported by them were used for providing further franchisee service to the sublicense for adopting McDonald s Restaurant system provided by the Noticee. xxxxxxx xxxxxxx xxxxxx 2. Here, I find that Franchisee service imported by the Noticee has nothing to do with the Management Consultancy service provided by the Noticee to their parent compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... franchisees Connaught Plaza in Delhi and Hardcastle in Mumbai. The Appellant had taken cenvat credit on reverse charge payment and utilized the same for payment of service tax on the export of management consultancy services by the Appellant from India to McDonald s USA in terms of the agreement dated 01 April, 1999. This payment of service tax was made in view of the condition under the Export of Service Rules, 2005 that required service to be delivered out of India for use outside India. This provision was subsequently altered with effect from 02 February, 2010. The issue is, therefore, restricted to the period 2007-08 to 2009-10 in the first show cause notice dated 17 August, 2013 and does not arise under the subsequent show cause notices. 56. The conclusion drawn by the Principal Commissioner is that the import of franchise service has nothing to do with the management consultancy service provided by the Appellant to McDonald s USA and, therefore, is not an input service is not correct. Firstly, there is no one-to-one correlation for the utilization of input service as long as the same qualifies as an input service in terms of Rule 3(1) of the Cenvat Rules a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... incipal Commissioner on this issue are as follows : 1. As regards the issue related to non-payment of service tax on Management Consultancy Service by wrongly claiming it as Export, I find that the department s case basically rest on the premise that the Management Consultancy service will be qualified for Export of Services when payment of such service is received by the service provider in convertible foreign exchange. As the payment has not been received, the department concluded that the Services are not Export of Service. 2. I find that the Noticee has been providing Management consultancy services to its parent company McDonald, USA and discharging service tax liability upto 27-02-2010. However, w.e.f. 27.2.2010, after amendment in Export of Services Rules 2005 made vide Notification No. 6/2010-ST dated 27.2.2010, they claimed their service i.e. Management Consultancy service as export of service in terms of Export of Services Rules, 2005. xxxxxxx xxxxxxx xxxxxx 3. In the instant case I find that the Noticee was asked to furnish export invoices raised by them for provisions of service and FIRCs t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e full value of goods or services within a stipulated period from the date of exports which in any case does not exceed more than one year. In view of the same I do not found any merit in Noticee s argument. [emphasis supplied] 60. The relevant Rule 3(2) of Export Rules is as follows : 3 . Export of taxable service (1) (2) The provision of any taxable service specified in sub-rule (1) shall be treated as export of service when the following conditions are satisfied, namely:- (a) -------- [omitted] (b) payment for such service is received by the service provider in convertible foreign exchange. 61. Rule 3(2) of the Export of Service Rules 2005 states that provision of any taxable service to qualify as export has to satisfy the condition that payment for such services is received in convertible foreign exchange. 62. While examining the reply of the Appellant, the Principal Commissioner has relied upon the requirement contained under the Reserve Bank of India Regulations that require the export proceeds to be realized wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are associated enterprises , in terms of the relevant provisions of the Income Tax Act, 1961. xxxxxxx xxxxxxx xxxxxx 4. I do not find any force in the above agreements for the reason that above stated administrative convenience and mutual understanding was contrary to the agreement on record. In absence of any documentary evidence to substantiate the administrative convenience and mutual understanding , I find it to be intentional and deliberate to delay the payment of tax. 65. The Principal Commissioner grossly erred in comparing the two tax payments namely those in respect of local franchisees under forward charge and those in respect of overseas payment of franchisee fee under the reverse charge. The former is under section 66 of the Act while the latter is under section 66A of the Act during the relevant period. 66. Forward charge under section 66 of the Act is in respect of service provided or to be provided and it is only from 1 July, 2011 that the Point of Taxation Rules, 2011 were brought into force. Therefore, for the period 2007-08 to 2010-11, the tax payment is linked to the receipt in ..... 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