ORDER – IN – APPEAL - Central Excise, Ahmedabadsevakarahmedabad.nic.in/doc/CA/122 to 128-2012.doc · Web viewORDER – IN – APPEAL M/s Cadila Healthcare Limited, Zydus Tower,

V2 (ST)112/A-IV/2012

ORDER – IN – APPEAL

M/s Cadila Healthcare Limited, Zydus Tower, Satellite Cross Road,

Opp. Iscon Temple, Ahmedabad-380 015 (hereinafter referred to as “the appellants”)

have filed the following appeals against the OIOs, as detailed below;

Sr. No. Appeal number OIO number & date Refund Amount of Rs.

Interest Rs.

1 112/A-IV/2012 STC/Ref./98/Nimba Ram-AC/Div.-III/11-12 dtd.18-11-2011

5,04,70,000/- 3,13,707/-


4,22,30,000/- 3,60,969/-


4,27,45,000/- ------


3,96,55,000/- --------


2,36,900/- ----------


2,52,350/- 1369/-


4,42,90,000/- ------------

TOTAL 21,98,79,250/-

All the above mentioned OIOs (hereinafter referred to as “the impugned

orders”) have been passed by the Assistant Commissioner, Service Tax, Division-III,

Ahmedabad (hereinafter referred to as “the adjudicating authority”).

Since the main issue involved in all the above appeals is identical, I take up all

the appeals together for decision.

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2. The brief facts of the case are that the appellants are engaged in the

manufacturing of pharmaceutical products and providing various services like

‘Maintenance or Repair Service’, ‘Advertising Agency Service’, ‘Intellectual Property

Service’, ‘Consulting Engineer Service’, ‘Management Consultants Service’,

‘Manpower Recruitment Agency Service’, ‘Business Auxiliary Service’, ‘Scientific and

Technical Consulting Service’, ‘Online Information & Database Retrieval Service’

Market Research Agency Service’ ‘Business Support Service’, ‘Clearing &

Forwarding Service’, ‘Renting of Immovable Property Service’, ‘Recovery Agents

Service’, ‘Technical Inspection & Certification Service’ and ‘Banking & Other

Financial Service’ and having Service Tax registration no. AAACC6253GST001. The

appellants have filed refund under the provisions of Section 11B of the Central

Excise Act, 1944 made applicable to Service Tax vide Section 83 of the Finance Act,

1994. The appellants i.e. M/s Cadila Healthcare Ltd. have received an amount of Rs.

2,13,00,00,000/- during the April,2010 to June,2011 from the partnership firm M/s

Zydus Healthcare towards ‘Partners remuneration’ and Rs.47,50,000/- towards

royalty in form of trade mark used during 2010-11. The appellants have paid service

tax of Rs. 21,93,90,000/- alongwith interest under ‘Business Auxiliary Service’ and

Rs.4,89,250/- under ‘Intellectual Property Right’ service, on the amount received

from M/s Zydus Healthcare as detailed above. The appellants have filed the present

refund claims on the ground that there existed a relationship of partner and

partnership firm between the appellants and M/s Zydus Healthcare under the

Partnership Act, 1932. That being a partner of M/s Zydus Healthcare, the appellants

were not rendering any services to M/s Zydus Healthcare, hence there cannot be

any service tax implications in respect of the payment received by the appellants

from M/s Zydus Healthcare for rendering any of the services. On scrutiny of the

refund claims, it was seen that as per the legal provisions of the Partnership Act, the

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services provided by M/s Cadila Healthcare Ltd. to M/s Zydus Healthcare do not fall

under those provisions and hence the service provider i.e M/s Cadila Healthcare Ltd.

is liable to pay service tax on the amount received by them from the service receiver.

Accordingly the refund request by the appellants was not as per the provision of law,

and therefore the appellants were not eligible for refund. In view of the ineligibility of

the refund, SCNs were issued to the appellants proposing to reject the refund claims.

The said SCNs were adjudicated by the adjudicating authority vide impugned orders

wherein he has rejected the refund claims being not admissible under Finance Act,

1994 and Service Tax Rules, 1994.

3. Being aggrieved with the impugned order, the appellant filed the above

mentioned appeals. In their appeal memorandum the appellants contented; that they

have made various submissions but the adjudicating has clearly overlooked the

submissions and has not discussed the case laws cited by them; that the impugned

orders do not specify under which clause of Section 65(19) of the Finance Act, 1994,

the service have been provided and also travels beyond the scope of show cause

notice; that the SCN has alleged that the appellants have provided services that of a

commission agent which is covered under the ‘Business Auxiliary Service’; that the

main activity of the commission agent is to cause sale or purchase of goods or

provision or receipt of services for a consideration on behalf of another person but in

the present case, the appellant have not caused any sale or purchase of goods on

behalf of another person; that they have not dealt with any goods or services or

documents of title to such goods; that in the SCN it has been alleged that the

appellants have provided the service of a commission agent but the impugned order

has failed to substantiate as to how the appellants can be construed as commission

agent; that the activities carried out by the appellants do not fall under the category

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of a commission agent, the impugned order deserves to be set aside; that in the

cases of ‘intellectual property right’ service, the adjudicating authority has not

brought out any material on record to show that the appellants have provided any

intellectual property service and has not specified that under which clause the

activity carried out by the appellants falls; that a combined reading of Sections 4, 25

and 26 of the Partnership Act, 1932 provides that any partner can carry the business

on behalf of the firm and individually they are called ‘Partners’ and collectively ‘the

firm’ and accordingly, the partners and the partnership firm are not separate and

there is no difference in partner whether he is natural person or juristic person. The

appellant relied upon a number of case laws which claimed to be in their favour such

as in the case of M/s Munshi Ram Vs Municipal Committee [1973 (3) SCC 83], M/s

V. Subramaniam Vs. Rajesh Raghuvendra Rao [2009 (5) SCC 608], M/s Regional

Director, ESI Corpn. Vs. Ramanuja Match Industries [1985 (1) SCC 218], M/s

Keshavji Ravji & Co. Vs. CIT [1990 (2) SCC 231] etc. The appellants further

contented that Section 10(2A) of the Income Tax Act, 1961 provides that in the case

of a partner of a firm, his share in the total income of the firm shall be exempt from

tax and that the partner and the partnership firm are the same entity, and the firm

bore the burden of tax on its profit/income then it would amount to double taxation if

the tax is once again levied from the partner; the partner and the firm are the same

entity and one cannot provide services to himself and therefore, it cannot be said

that the appellants have provided services to the firm; that a firm is strictly not a

person or a legal entity distinct from its member composing it and does not have an

independent existence; that as per Section 4 of the Partneship Act, 1932, it is very

clear that a firm is not a legal entity and it is merely a collective term of partners who

have entered into a partnership with one another. For this view they relied upon the

decision in the case laws of M/s Bharat Sarvodaya Mills Co. AIR 1969 Guj. 179, M/s

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R.M. Chidambaram Pillai [1970 (77) ITR 494] etc. He further contented that the ratio

of all the decisions mentioned would state that the partner and the partnership firm

are same and one entity and the partner cannot be said to be providing services to

the firm and on this ground the service tax paid erroneously by the appellants are

entitled to be refunded; that in the Central Excise Law, Customs Law and Service

Tax law it is well established that when penalty is imposed on the partnership firm

then separate penalty cannot be imposed on the partner of the firm and the rational

behind this is that the partner and the firm are same person and therefore, separate

penalty cannot be imposed; that in the case law relied upon by the adjudicating

authority, the Tribunal while rendering the said decision had not considered the law

laid down in this regard by the Supreme Court; that they relied upon the decision of

Bombay HC in case of Jupiter Exports [2007 (213) ELT 641]; that Board vide letter

DY No. 324/COMM(Service Tax)/2008 dated 01.12.2008 clarified that the

commission paid by the companies to their officials such as Directors cannot be in

the nature of service; that the contention of the adjudicating authority that the

appellants have not complied with Section 16 of the Partnership Act is erroneous as

the appellants have done all the activities as agreed in the partnership deed. The

appellants further requested to set aside the impugned order and allow the appeals

in full with consequential relief.

4. Personal hearing in all the above case was granted on 10.04.2012

wherein Shri Gopal Chosla, Gen.Manager-Excise, on behalf of the appellants

appeared before me and reiterated the grounds of appeal and requested to allow the

refund.

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DISCUSSION AND FINDINGS

5. I have gone through the facts of the case, the appellants grounds of

appeal in the appeal memorandum and oral submissions made by them at the time

of personal hearing.

6. The appellants have filed the refund on the ground that the partners and

partnership firm are one and the same and one person cannot provide any service to

himself. I find that the appellants have entered into a partnership agreement with M/s

Cadila Healthcare Staff Welfare Trust and German Remedies Ltd and formed a

partnership firm I.e Zydus Healthcare and shares 96% of profit/loss. As per the

agreement, Zydus Healthcare used the marketing and distribution set up of Cadila

Healthcare Ltd. (appellants) for selling the pharmaceutical products in India. For

undertaking the activities, the appellant has been paid remuneration as mutually

agreed upon and the remuneration received by the appellants is booked as ‘Partners

remuneration from Partnership Firm’ in the books of accounts of the appellants. The

appellants have also received amount from M/s Zydus healthcare for allowing M/s

Zydus healthcare to use the trade mark. The appellants claimed that they being a

partner of the firm, rendering of any services to Zydus Healthcare can only be treated

as service rendered to itself and hence there cannot be any service tax implications in

respect of payment received by the appellants from Zydus Healthcare for rendering

any of the services.

7. I find that the appellants in their refund applications, narrated the

activities they carried out as partners of the firm wherein it has clearly indicated that

the appellants had undertaken following activities: -

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(i) providing the services relating to promotion and marketing of the firms product including providing or marketing infrastructure, product development and promotion, information database, IT and other system support and inventory supply chain management,

(ii) Functioning as ‘consignment and sale agent of the firm for storage and distribution of firms products throughout India,

(iii) Collection of money due to the firm for the sales of products made by and on behalf of the firm,

(iv) After sales services to the Customers of the firm,

(v) Selecting and appointing stockeist for Distribution of the firm’s products,

(vi) Guiding and helping in procurement of inputs such as raw materials, packing materials, consumables, plant and machinery, equipments for the firm,

(vii) Providing legal, technical and managerial assistance for the smooth and efficient conduct of the business of the firm.

For undertaking the above activities the appellants have received remuneration from

the firm, M/s Zydus Healthcare. I find that these activities fall within the purview of

‘Business Auxiliary Service’. For the sake of reference, I reproduce the definition of

‘Business Auxiliary Service’ as per the provisions of Section 65(19) of the Finance Act,

1994 as below;-

‘Business Auxiliary Service’ means any service in relation to,-

(i) Promotion or marketing or sale of goods produced or provided by or belonging to the client; or

(ii) Promotion or marketing of service provided by the client; or

(iii) Any customer care service provided on behalf of the client; or

(iv) Procurement of goods or services, which are inputs for the client; or

(v) Production or processing of goods for, on behalf of, the client; or

(vi) Provision of service on behalf of the client; or

(vii) a service incidental or auxiliary to any activity specified in sub-clauses (i) to (vi), such as billing, issue or collection or recovery of cheques, payments, maintenance of accounts and remittance, inventory management, evaluation or

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development of prospective customer or vendor, public relation services, management or supervision,

and includes services as a commission agent, but does not include any information technology service and any activity that amounts to “manufacture” within the meaning of clause (f) of section 2 of the Central Excise Act, 1944 (1 of 1944).

Explanation. - For the removal of doubts, it is hereby declared that for the purposes of this clause, “commission agent” means any person who acts on behalf of another person and causes sale or purchase of goods, or provision or receipt of services, for a consideration, and includes any person who, while acting on behalf of another person –

(i) deals with goods or services or documents of title to such goods or services; or

(ii) collect payment of sale price of such goods or services; or

(iii) guarantees for collection or payment for such goods or services; or

(iv) undertakes any activities relating to such sale or purchase of such goods or services;

On a plain reading of the definition of ‘Business Auxiliary Service’ as provided above,

the activities carried out by the appellants are appropriately classifiable under Sub-

clause (vii) of the above said definition and hence the services rendered are taxable

services under ‘Business Auxiliary Service’. They are also registered with service tax

department and are paying service tax under the said category. The appellants

contented that the show cause notice has alleged that they have provided the services

that of a commission agent to the partnership firm, but they cannot be termed as

‘commission agent’ to be covered under the taxable category of Business Auxiliary

Service’, as they have not caused any sale or purchase of goods on behalf of another

person. On going through the records, I find that the SCN has never specifically

categorized the service provided by the appellants as that of a ‘commission agent’.

The adjudicating authority while explaining the definition of ‘Business Auxiliary Service’

and comparing the service with the activities of the appellants, only concluded that as

per the provisions and explanation of the service tax law, the services provided by the

appellants to M/s Zydus Healthcare fulfilled the requirement as mentioned in the sub-

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section (vii) of the definition. I find that sub-clause (vii) of the definition covers all the

activities incidental or auxiliary to the services specified in previous clauses (i) to (vi)

which includes the service of a ‘commission agent’. The activities of the appellants

which I have mentioned earlier in this paragraph are much more than that of a

commission agent but clearly and categorically comes under the definition of ‘Business

Auxiliary Service’. Hence, the contention of the appellant does not hold any merit and

the case law relied upon by them in this regard does not support them. I find that the

appellants have also received amount as royalty for allowing to use their licence trade

mark in respect of the products to M/s Zydus healthcare and the said activity carried

out by the appellants fall under the category of ‘intellectual property service’ and the

appellants have rightly paid the service tax on the said amount.

8. The next contention of the appellants is that the ‘Partners’ and

‘Partnership firm’ are one and the same hence a ‘partner’ rendering service to the firm

is not liable to Service Tax. I find that the appellants themselves classified the services

rendered by them under the category of ‘Business Auxiliary Service’ and ‘Intellectual

Property Service’ and paid Service Tax accordingly. Even after they had provided

service under ‘Business Auxiliary Service’ and ‘Intellectual Property Service’ and also

paid service tax thereon for the value received by them on self assessment, they have

filed the refund claims on the ground that a ‘partner’ and the ‘partnership firm’ are one

and same and one cannot provided service to himself. Section 65(105)(zzb) defines

taxable service of ‘Business Auxiliary Service’ as “any service provided or to be

provided to a client by any person in relation to business auxiliary service”. Even if the

term ‘person’ has not been defined in the context of service tax, but as per clause (42)

of Section 3 of General Clause Act, 1897, ‘person shall include any company or

association or body of individual, whether incorporated or not’. Accordingly person

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would include all person – natural and juristic i.e. artificial persons created by an act or

law such as HUF, company, corporation, co-operative society, registered firm, trust,

govt. agencies etc., whether engaged in commercial activity or not. The dictionary

meaning of ‘client’ provides that a client means ‘a person who uses the services or

advice of a professional person or organization’. From the records, it is apparent that

the appellants have rendered the service of ‘Business Auxiliary Service’ ‘intellectual

property service’ to M/s Zydus Healthcare and received consideration and paid service

tax on the same. Hence the transactions between the appellants and Zydus

Healthcare, come under the purview of Service Tax under the category of ‘Business

Auxiliary Service’ and ‘Intellectual Property Service’.

9. The appellants claimed that the partner and partnership firm are one and

the same and the partnership firm is not a separate legal entity. This contention

appears to be twisting the facts to suit their needs. It is a fact that an individual partner

and the partnership firm have independent existence and the partnership firm is a

separate legal entity. The partnership firm is formed under the Indian Partnership Act,

1932. As per Section 4 of the Partnership Act, ‘partnership’ is the relation between

persons who have agreed to share the profit/loss of a business carried on by all or any

of them acting for all. Person who have entered into partnership with one another are

called individually ‘partners’ and collectively a ‘firm’ and the name under which their

business is carried out is called the ‘firm name’. The partners are entitled to share

equally in the profit earned, and shall contribute equally to the losses sustained by the

firm. This will no way affect the independent existence of the partnership firm as a

separate legal entity.

10. Further I find that the appellants i.e M/s Cadila Healthcare Ltd. and M/s

Zydus Healthcare are not related to each other in view of the Schedule IA of Section

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2(41) of the Companies Act, 1956 and hence the services provided by the appellants

to another company M/s Zydus Healthcare are independent in nature and the

monetary benefit earned out of it attracts the provisions of Service Tax. From the

records, it is seen that both the appellants and Zydus Healthcare are separate legal

entities and both have separate financial records and are separately assessed to

service tax as well as income tax. If they are one and same entity there would have

only one financial record, one common assessment and also common bank account.

In the absence such conditions, it cannot be claimed that they are one and same.

Hence, the services rendered by the appellants cannot be considered as services

rendered by a partner to the partnership firm. The services rendered are in their

individual capacity and hence the remuneration received by the appellants for

providing taxable service, shown in the account head of the appellants as ‘partner’s

remuneration from a partnership firm’ is liable for service tax. In view of the above

discussions, I hold that he appellants have provided taxable service under ‘Business

Auxiliary Service’ and ‘intellectual property service’ and they are liable for service tax

under the said category on the remuneration received by them. Accordingly, the

Service Tax paid by them is in order. Therefore, the appellants are not eligible for

refund of the service tax paid by them.

11. Further I find that under Section 4 of the Partnership Act, 1932,

‘partnership’ is defined as the relation between persons who have agreed to share the

profit of a business carried on by all or any of them acting for all. Section 4 (7) (iii) says

that a mere common interest and, as such sharing of profits, cannot, by itself,

constitute a partnership unless there is a common business. I find that the appellants

and the partnership firm have no common business. The appellants have their own

manufacturing activity and in addition to that they are engaged in the activity of

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marketing the pharmaceutical products manufactured by M/s Zydus Healthcare.

Section 13 of the Partnership Act deals with the mutual rights and liabilities, subject to

contract between the partners. It provides that (a) a partner is not entitled to receive

remuneration for taking part in the conduct of the business; (b) the partners are

entitled to share equally in the profits earned, and shall contribute equally to the losses

sustained by the firm; (c) where a partner is entitled to interest on the capital

subscribed by him, such interest shall be payable only out of profit; …. From the

above, I find that the appellants are not liable to receive remuneration from partnership

firm for the services rendered as a ‘Partner’. On going through the financial records of

the appellants and M/s Zydus Healthcare, it is noticed that the appellants have

received remuneration (income) under the head ‘Partners remuneration from

Partnership firm’ which is accounted as ‘Partners Remuneration’ in the books of

account of M/s Zydus Healthcare under General Expenses. It is also seen in the books

of account of the appellants that they have received ‘Share of Profit from the

Partnership Firm’ as well as ‘Interest earned on Capital in a Partnership Firm’. This

shows that the income received under ‘share of profit from a partnership firm’ and

‘interest earned on capital in a partnership firm’ are derived out of the partnership

agreement of the appellants. But the income received under the head ‘Partner’s

remuneration from a partnership firm’ was not derived from the partnership agreement

in view of the Section 13 of the Partnership Act. As per the partnership agreement

dated 01.03.2007, it has been agreed to share the profit /loss among the three

partners as 96% to the appellants and 2% each for other two partners. The profit

received from the partnership firm has been accounted separately in the books of

accounts of the appellants. The agreement deals with profit sharing only. The

agreement does not deal with the services rendered by the appellants as a ‘partner’.

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Hence, the remuneration received by the appellants was not as a part of the

partnership agreement.

12. I also find that the appellant’s company is a Limited company. It has a

vast pool of manpower and a network of depots and dealers across the country. The

appellant have provided the service using this vast pool of resources. It is not a case

of an individual partner rendering services to its Partnership Firm. It is a case of

Limited Company through its vast pool of manpower and network of depots and

dealers rendering services to another firm. So, the services rendered are not by an

individual partner. Hence, the remuneration received is to be treated as remuneration

received by the Limited Company for usage of its manpower and resources. Hence,

the services rendered cannot be treated as services rendered by a partner to the

partnership firm. I also find that the income received under the head ‘Partner’s

Remuneration from Partnership firm’ is not derived out of partnership agreement, but

earned only for the activities/services provided as mentioned in above paragraph by

the appellants in their individual capacity to M/s Zydus Healthcare

13. The appellant relied upon a catena of decisions of various authorities in

support of their claim. The decision in the case of M/s Munshi Ram and others Vs.

Municipal Committee, Chheharta, which relates to tax on profession based on Punjab

Municipal Act, 1911 entirely different from the service tax provisions involved in the

present issue. Similar in the case of V. Subramaniam Vs. Rajesh Raghuvandra Rao, is

related to dissolution of unregistered firm which also not akin to the facts of the

present issue. In the case of Regional Director, ESIC, Trichur Vs. Ramanuja Match

Industries, it is related to the ownership of partners in a partnership firm and not

applicable to the present case. I find that the case law of Keshavji Ravji and Co. and

Others Vs. Commissioner of Income Tax, is related to the non-deductibility of income

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tax on the interest received from the partners on his borrowings from the firm. These

case laws are not relevant to the matters related to service tax and hence they do not

come to the support of the appellants.

14. I find that the decision of of Kolkatta Tribunal in the case of M/s Sushant

Agarwal reported in 2008 (10) STR 529 (Tri.Kolkatta) is more apt to the present case

wherein it has been held that the partnership firm is formed under the Indian

Partnership Act, 1932 and the partnership firm has separate legal entity. The individual

partners of the partnership firm are independent from the partnership firm, therefore, it

is totally incorrect to say that they are one and the same and to say they are one and

same is beyond legal comprehension. Relying upon this case and the arguments

cited in the previous paras, I hold that the services rendered by the appellants are not

as a part of the partnership agreement and has been performed by the appellants in

their individual capacity to another firm. The remuneration received towards the

services rendered are not ‘Partner’s remuneration’ as the appellants have received

their share of profit separately. Further this remuneration to the services rendered has

been given only to the appellants and not to the other partners. The agreement does

not specify the nature of services to be rendered by the partners to the partnership

firm. Hence, I hold that the remuneration received by the appellants towards ‘Business

Auxiliary Service’ rendered by them in their individual capacity, is liable to Service Tax

under ‘Business Auxiliary Service’. The appellant has rightly paid Service Tax under

‘Business Auxiliary Service’ and hence the refund applications are liable to be

rejected.

15. Further, I also find that the appellants have paid service tax on self

assessment. They have not challenged the self assessment. The department has not

questioned the self-assessment done by the appellants. Hence, the self assessment

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made by the appellants need to be challenged and nullified by them before filing the

refund claim. Before that, the question of claiming refund does not arise. This view has

been supported by various judgments of Tribunals. In the case of M/s KEC

Internationals reported in 2006 (4) STR 473 (Tri.-Del.), it has been held that payment

of tax by self-assessment without request/direction from the department, is valid

discharge of service tax and not liable to be refunded, irrespective of it being paid

under protest. Same view has taken by the Tribunal Mumbai in case of M/s

Maharastra Cylinders Pvt. Ltd. reported in 2010 (259) ELT 369 (Bom.) and Chennai

Tribunal in case of M/s E.I.D. Parry India Ltd. reported in 2006 (4) STR 585 (Tri.-

Chennai). In view of the above discussion, I hold that the refund is liable to be

rejected. In view of the above, I pass the following order:

ORDER

16. In view of the foregoing discussions, I uphold the impugned orders

passed by the adjudicating authority and reject the all the appeals filed by the

appellants.

Sd/- ( 17.04.2012)(K. ANPAZHAKAN)

COMMISSIONER (APPEAL-IV)CENTRAL EXCISE, AHMEDABAD.

ATTESTED Date : .04.2012

(H.K. JAIN)SUPERINTENDENT (APPEAL-IV)CENTRAL EXCISE, AHMEDABAD.BY R.P.A.D.

To : M/s Cadila Healthcare Ltd., Zydus Tower, Satellite Cross Roads, Ahmedabad – 380 015.

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Copy to :-1. The Chief Commissioner, Central Excise, Ahmedabad Zone, Ahmedabad.2. The Commissioner, Service Tax, Ahmedabad.3. The Assistant Commissioner, Service Tax, Division-III, Ahmedabad4. The Assistant Commissioner, Service Tax,(Systems), Ahmedabad5. Guard file. 6. P.A. file.7. F. No. V2(ST)113/A-IV/20128. F. No. V2(ST)114/A-IV/20129. F. No. V2(ST)115/A-IV/201210. F. No. V2(ST)116/A-IV/201211. F. No. V2(ST)115/A-IV/201212. F. No. V2(ST)192/A-IV/2012

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Documents

ORDER – IN – APPEAL - Central Excise, Ahmedabadsevakarahmedabad.nic.in/doc/CA/122 to 128-2012.doc · Web viewORDER – IN – APPEAL M/s Cadila Healthcare Limited, Zydus Tower,