Madras High Court
M/S Josco Rubber Industries vs The Commercial Tax Officer Iac on 29 April, 2026
Author: Anita Sumanth
Bench: Anita Sumanth
T.C.No.47 of 2011
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Date of Reserving the Order Date of Pronouncing the Order
23.02.2026 29.04.2026
CORAM:
THE HONOURABLE DR.JUSTICE ANITA SUMANTH
AND
THE HONOURABLE MR.JUSTICE MUMMINENI SUDHEER KUMAR
T.C.No.47 of 2011
and
M.P.No.1 of 2011
M/s.Josco Rubber Industries
No.4, Romain Rolland Street
Puducherry
rep.by its Managing Partner
Abey Joseph ... Petitioner
-vs-
1.The Commercial Tax Officer (IAC)
Commercial Taxes Department
Puducherry
2.The Appellate Assistant Commissioner
Commercial Taxes Department
Puducherry ... Respondents
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PRAYER: Tax Civil Revision Petition filed under Section 42 of the Puducherry
General Sales Tax Act, 1967, to revise the Judgment and Order of the Sales Tax
Appellate Tribunal (Principal District Judge), Puducherry, dated 07.01.2011,
passed in Tax Appeal No.4 of 2007.
For Petitioner : Mr.Joseph Markos, Senior Counsel
assisted by Mr.R.Anish Kumar
For Respondents : Mr.J.Kumaran
Additional Government Pleader (Pondy)
ORDER
MUMMINENI SUDHEER KUMAR, J.
This tax revision petition is directed against the order dated
07.01.2011, passed in Tax Appeal No.4 of 2007, on the file of the Appellate
Tribunal under the Puducherry General Sales Tax Act, 1967 (hereinafter, referred
to as the “PGST Act”), at Puducherry.
2. The revision petitioner herein is the manufacturer of Hawai
Chappals and Hawai Soles at Kirumampakkam, Puducherry and registered under
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the provisions of the PGST Act and was assessed to tax for the year 1997-1998.
The total turnover of the revision petitioner herein as declared and determined was
Rs.6,74,717/- with no exempted turnover and an amount of Rs.9,632/- was paid as
tax. However, during the verification of the assessment records, the Assessing
Officer noticed that an amount of Rs.35,27,874/- was received by the revision
petitioner herein during the year 1997-1998 towards royalty from M/s.Jasco
Footwear Products, having its Factory at No.9, Pipdic Industrial Estate,
Kirumampakkam, Pondicherry, for usage of the brand name of “Miami Cushion”.
The Assessing Officer, having taken a view that the since brand name itself
constitutes an intangible property having intangible and incorporeal character
being capable of bought and sold, and hence the said royalty income is liable to
tax at 3% under entry 23 of Part D of Schedule- and proposed for revision of the
assessment order and accordingly, issued the notice dated 19.04.2002.
3. In response thereto, the revision petitioner submitted its reply
stating that the royalty received by the revision petitioner herein is not liable to tax
under PGST Act, on the ground that only the movable property comes within the
definition of “goods” in PGST Act and liability to pay tax would arise only when
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there is a sale as per definition under Section 2(p) of PGST Act. Thus, it is
contended that there is no transfer of property in goods and therefore, the
transaction in question is not a sale. It is also further contended that there was no
transfer of right to use the brand name “Miami Cushion” and the said right
continued to be with the revision petitioner herein without any let up or
interruption or break and explained in detail, the nature of the agreement dated
01.04.1997 that was entered into between the revision petitioner herein and
M/s.Josco Footwear Products (hereinafter referred to as JFP. The Assessing
Officer, having considered the reply submitted by the revision petitioner herein,
came to the conclusion that in terms of the said agreement dated 01.04.1997, the
revision petitioner has agreed to confer the right to use the said brand name in
favour of M/s.Josco Footwear Products subject to various terms and conditions
mentioned in the said agreement. Therefore, the transaction between the revision
petitioner and M/s.Josco Footwear Products would amount to sale within the
meaning of “sale” defined under Clause (p) of Section 2 of PGST Act and
accordingly, levied tax on the amount of Rs.35,27,874 being the royalty amount
received by the revision petitioner herein at the rate of 3% amounting to
Rs.1,05,836/-.
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4. It was aggrieved by the said order, the revision petitioner herein
filed an appeal No.8/PGST/04-05 before the Appellate Assistant Commissioner,
Commercial Taxes Department, Government of Puducherry, reiterating its
contentions and also raising an additional ground that in terms of a Notification
issued by the Government in G.O.Ms.No.50/90/F6, dated 10.12.1990 (hereinafter,
referred to as the “Notification”), the transfer of right to use any goods for any
purpose is exempted from payment of tax due under the PGST Act and therefore,
the royalty amount in question cannot be subjected to tax. However, the
representative appearing for the State Government contended that by virtue of the
introduction of Section 3-A into the PGST Act with effect from 01.04.1997, the
Notification dated 10.12.1990 is deemed to have been superseded and therefore,
the revision petitioner herein cannot claim the benefit of the said Notification.
5. The Appellate Assistant Commissioner, Commercial Taxes
Department, having examined the matter in detail, concurred with the findings of
the Assessing Officer, and also rejected the contentions raised by the revision
petitioner herein by placing reliance on the Notification dated 10.12.1990 and
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agreed with the contentions of the representative of the State Government, by
order dated 23.04.2007.
6. It was aggrieved by the said order, the revision petitioner herein
filed a Tax Appeal No.4 of 2007, before the Appellate Tribunal under the PGST
Act at Puducherry and the said appeal came to be dismissed by the Appellate
Tribunal by Judgment dated 07.01.2011. It was aggrieved by the said order, the
revision petitioner is before this Court.
7. On 23.06.2011, while this tax revision case was admitted, the
following substantial questions of law have been framed:
“1.Whether on the facts and in the circumstances of the
case, royalty received by the petitioner on the licence granted to
use its trade mark “Miami Cushion” is taxable under the PGST
Act?
2.Whether on the facts and in the circumstances of the
case, the findings of the Appellate Tribunal that the petitioner is
not entitled to the benefits of exemption notification
G.O.Ms.No.50/90/F6 dated 10.12.1990 is right in law?
3.Whether on the facts and in the circumstances of the
case, the Appellate Tribunal was right in holding that Section 3A is
applicable to the petitioner in supersession of exemption____________
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notification G.O.Ms.No.50/90/F6, dated 10.12.1990.”
8. We have heard Mr.Joseph Markos, learned Senior Counsel assisted
by Mr.R.Anish Kumar, learned counsel on record for the revision petitioner and
Mr.J.Kumaran, Additional Government Pleader (Pondy) appearing for the
respondents.
9. There is no dispute on the factual aspects of the matter. Right to
use the trademark / brand name “Miami Cushion” was granted in favour of
M/s.Josco Footwear Products under the agreement dated 01.04.1997 subject to
payment of royalty at the rate of Rs.2.00 per pair for prime pair of chappal and
Rs.1.25 paise per pair for second quality chappals sold in the market by M/s.Josco
Footwear Products.
10. Learned Senior Counsel appearing for the revision petitioner
having taken us through the detailed contents of the agreement dated 01.04.1997
contended that there was no transfer of right in the trademark in favour of
M/s.Josco Footwear Products under the said agreement and all the rights over the
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trademark are retained by the revision petitioner herein with a specific power to
transfer it to any other third party or to lease out to the third party, including the
right to sell or mortgage the same. Therefore, there is no transfer of right in the
trademark in favour of M/s.Josco Footwear Products. He also further contended
that the trademark is not an immovable property so as to come within the meaning
of “Goods” to attract the provisions of the PGST Act. He also further contended
that by virtue of the Notification dated 10.12.1990, the transfer of right to use is
exempted from payment of tax due under the PGST Act and the subsequent
introduction of Section 3-A into the PGST Act cannot have any impact on the
effect of the said Notification. In support of his contentions, he placed reliance on
a subsequent Notification issued under G.O.Ms.No.64/F2/2008, dated 16.10.2008,
whereby various Notifications, including the Notification dated 10.12.1990, came
to be rescinded by the Government of Puducherry and contended that in case if
there is any deemed supersession of the Notification dated 10.12.1990, there was
no necessity for the Government to issue the Gazette Notification dated
16.10.2008 rescinding the Notification dated 10.12.1990. In support of his
contentions, he also placed reliance on the following decisions of the Honourable
Apex Court and various High Courts:
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(a) Bharat Sanchar Nigam Ltd., and another vs. Union
of India and others, reported in (2006) 3 SCC 1;
(b) Judgment dated 24.06.2013, rendered in W.A.No.22313
of 2012 (Malabar Gold Private Limited vs.
Commercial Tax Officer, Kozhikode and others)
(Kerala High Court);
(c) Judgment dated 17.05.2017, rendered in S.T.A.No.26
of 2013 (McDonalds India Pvt. Ltd., vs.
Commissioner of Trade & Taxes) (Delhi High Court);
and
(d) Tvl.Vitan Departmental Stores and Industries Limited
vs. State of Tamil Nadu, reported in (2014) 45 GST 95
(Mad).
11. On the other hand, learned Additional Government Pleader
appearing for the respondents contended that the issue as to whether trademark /
brand name would come within the meaning of “immovable property / goods”
within the meaning of the provisions contained in the PGST Act is no more res
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integra as the same was already decided by this Court in the case of S.P.S.Jayam
and Co., vs. Registrar, Tamil Nadu Taxation Special Tribunal and others,
reported in 2004 SCC OnLine Mad 1018. He also further contended that by
virtue of the introduction of Section 3-A into the PGST Act with effect from
01.04.1997, every dealer is made liable to pay tax on his taxable turnover relating
to the business of transfer of right to use any goods for any purpose at the rate
mentioned in Sub-Section (2) of Section 3 or as the case may be in Section 4.
Hence, by implication whatever exemptions that were granted under the
Notification dated 10.12.1990 would automatically stand superseded. In support
of his contention, he drew the attention of this Court to various findings rendered
by the Appellate Assistant Commissioner and the Appellate Tribunal placing
reliance on the decisions of the Honourable Apex Court in the case of
Commissioner, Sales Tax, U.P. vs. Agra Belting Works, reported in (1987) 66
STC 1 and decision of the Honourable Apex Court in the case of Sales Tax
Officer, Sector IX, Kanpur vs. Darling Dairy Products and another, reported in
(1994) 94 STC 93.
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12. We have carefully considered the submissions made on either side
and also perused the entire materials on record.
13. No much deliberation required on the factual aspects of the
matter. From the perusal of the agreement dated 01.04.1997, it is evident that the
right to use the trademark / brand name was granted in favour of M/s.Josco
Footwear Products subject to payment of royalty at the agreed rate. It is also not
in dispute that M/s.Josco Footwear Products, as a matter of fact, used the said
brand name and accordingly paid royalty to the revision petitioner herein during
the year 1997-1998. The contention of the learned Senior Counsel appearing for
the revision petitioner by placing reliance on the decision of the Honourable Apex
Court in Bharat Sanchar Nigam Ltd‘s case and other decisions of the Kerala
High Court and this Court cited supra, are all distinguishable and have no
application to the case on hand in the light of the admitted facts of this case. In all
the case of BSNL, the dispute was as to whether the subject matter of transaction
therein is a service or sale. So long as it was a service, the same was held to be
not liable to tax under Sales Tax Act, but, the other part of transaction amounting
to sale would be liable to tax. No doubt, in Bharat Sanchar Nigam Ltd‘s case,
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one of the learned Judge, while concurring with the final conclusion arrived at by
the majority of the Judgment, held as under at Paragraph No.97:
“97. To constitute a transaction for the transfer of the right to use the
goods the transaction must have the following attributes:
(a) There must be goods available for delivery;
(b) There must be a consensus ad idem as to the identity of
the goods;
(c) The transferee should have a legal right to use the goods
consequently all legal consequences of such use including any
permissions or licenses required therefor should be available to
the transferee;
(d) For the period during which the transferee has such
legal right, it has to be the exclusion to the transferor this is the
necessary concomitant of the plain language of the statute viz. a
“transfer of the right to use” and not merely a licence to use the
goods;
(e) Having transferred the right to use the goods during the
period for which it is to be transferred, the owner cannot again
transfer the same rights to others.”____________
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14. Those are the observations made in minority concurring
Judgment. The majority view was indicated at Paragraph No.92, while
answering the questions that were framed in Paragraph No.32. For better
appreciation, the questions that were framed in Paragraph No.32 and the answers
given in Paragraph No.92 under the majority Judgment are extracted hereunder:
Q.No. Question at Para 32 Answer at Para 92
A What are “goods” Goods do not include
in electromagnetic waves or radio
telecommunication frequencies for the purpose of
for the purposes of Article 366(29-A)(d). The goods
Article 366(29-A) in telecommunication are limited
(d)? to the handsets supplied by the
service provider. As far as the SIM
cards are concerned, the issue is
left for determination by the
assessing authorities
B Is there any There may be a transfer of
transfer of any right to use goods as defined
right to use any in answer to the previous
goods by providing question by giving a
access or telephone telephone connection.
connection by the
telephone service
provider to a
subscriber?
C Is the nature of the The nature of the
transaction transaction involved in
involved in providing the telephone
providing connection may be a
telephone composite contract of
connection a service and sale. It is
composite contract possible for the State to tax
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of service and the sale element provided
sale? If so, is it there is a discernible sale
possible for the and only to the extent
States to tax the relatable to such sale.
sale element?
D If the providing of The issue is left unanswered
a telephone
connection
involves sale, is
such sale an inter-
State one?
E Would the “aspect The 'aspect theory' would
theory” be not apply to enable the
applicable to the value of the services to be
transaction included in the sale of goods
enabling the States or the price of goods in the
to levy sales tax on value of the service.”
the same
transaction in
respect of which
the Union
Government levies
service tax?
15. In the concurring judgment of the learned Judge at Para 97 certain
conclusions were arrived at. In this connection, Para 75 of the majority judgment
is required to be noticed. The said paragraph reads as under:
75. In our opinion, the essence of the right under Article
366(29-A)(d) is that it relates to user of goods. It may be that the
actual delivery of the goods is not necessary for effecting the transfer
of the right to use the goods but the goods must be available at
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T.C.No.47 of 2011the time of transfer must be deliverable and delivered at some stage.
It is assumed, at the time of execution of any agreement to transfer
the right to use, that the goods are available and deliverable. If the
goods, or what is claimed to be goods by the respondents, are not
deliverable at all by the service providers to the subscribers, the
question of the right to use those goods, would not arise.
If the majority view is taken into consideration, the findings recorded therein are
in connection with the facts of that particular case. No doubt, in the minority
Judgment at Paragraph No.97, held that there must be goods available for delivery
and the owner of the goods having transferred the rights to use goods cannot again
transfer the right to use or can transfer the goods to others. As already noted
above, the above findings are by the concurring minority Judgment which will
have only persuasive value instead of binding nature. The conclusions arrived at
in the minority judgement are the basis for the Kerala High Court to arrive at its
conclusions in Malabar Gold case. The amendment made to Art. 366(29A) of the
Constitution of India is the basis for making the transfer of right to use goods
taxable. Right to use can be transferred either by way of Lease or Licence over
the goods both tangible and intangible. If the license is to be treated as the one
not coming within the scope of Section 3A, the same is nothing but causing
violence to the very provisions itself. A right in goods can be transferred either
permanently or temporarily. If it is permanent, it is by way of sale. If it is
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temporary for specified period, it will be by way of lease or license. What is
transferred in the case on hand is the right to use the trade mark within
Pondicherry only. When right to use is transferred for a specific period for a
specified area only, it cannot be said that the owner of the trade mark cannot have
right to transfer again or have no right to use the trade mark by itself. Therefore,
it is highly improbable to say that in order to attract Section 3A, the owner of
trademark also shall cease to have right to use the trade mark for the period during
which right to use such trade mark was transferred. Therefore, the BSNL case
and Malabar Gold case have application to the case on hand. In the case of
Mc.Donalds also an identical view was taken as in the case of Malabar Gold case
and in fact the Malabar Gold case was followed by Delhi High Court. For the
very same reasons as stated in respect of Malabar Gold case, Mc.Donalds case
also has no application to the case on hand. Further, the subject matter of both the
said cases decided by Kerala High Court and Delhi High Court have dealt with
Franchisee Agreements unlike in the present case.
16. In contrast to the decisions in Malabar and Mc.Donald cases, as
rightly pointed out by the learned Additional Government Pleader appearing for
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the respondents, this Court had an occasion to deal with the case, which is
identical in nature to the case on hand, in Jayam‘s case, wherein a Division Bench
of this Court, having elaborately considered various decisions of the Honourable
Apex Court, including the decision in the case of Vikas Sales Corporation vs.
Commissioner of Commercial Taxes, reported in (1996) 102 STC 106 (SC), at
Paragraph No.8, has held as under:
“8. Coming to the facts of the present case, the petitioner/ assessee
permitted M/s.Muthu Agencies to use their trademark in the course of trade
at the rates specified therein for various items during a particular period.
Of course, it retained the liberty to make use of the trademark in the event of
the licensor starting to manufacture the products. Equally, it retained the
liberty to grant licence to any other individual person or company to use the
trademarks. Trademark is the property right and it exclusively belongs to
the party who has registered it. Such a right is an intangible or incorporeal
goods, which can be merchandised by the registered owners. As pointed out
by the Supreme Court, the word “goods” is defined in very wide terms so as
to bring in both tangible and intangible objects. General Clauses Act would
explain movable property as property of every description except
immovable property. Trademark right is intangible goods, which can be
subject-matter of transfer. As already pointed out, M/s. Muthu Agencies was
granted permission to use the trademark without any restriction whatsoever
for a particular period. Consequently, it can only be taken as transfer of a
right to use and not a mere right to enjoy. Simply because the assessee
retained the right for himself to use the trademark and reserved the right to
grant permission to others to use the trademark, it would not take away the
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character of the transaction as one of transfer of a right to use. That being
so, this Court has to only hold that the order of the Tamil Nadu Taxation
Special Tribunal, Chennai, confirming the order of the Joint Commissioner-
III (SMR), Chepauk, is well in order.”
17. The said decision of this Court in Jayam‘s case was carried in
appeal in Civil Appeal No.1415 of 2010 before the Hon`ble Apex Court and the
order passed by this Court in Jayam‘s case was confirmed by the by order dated
18.01.2023. The facts of the present case are identical in nature as seen from
Paragraph No.8 of the decision of this Court, wherein it was held that the word
“goods” is defined in very wide terms so as to bring in both tangible and
intangible objects within the meaning of “goods”. In the said case, M/s.Muthu
Agencies was permitted to use the trademark of “M/s.S.P.S.Jayam and Company”
in the course of trade subject to payment at the rates as specified therein for
various items during a particular period, while retaining the liberty to make use of
the trademark like in the present case. The said transaction between
M/s.S.P.S.Jayam and Company vs. M/s.Muthu Agencies was considered to be a
transaction of sale within the meaning of sale. The decision in Jayam`s case was
followed by another learned Division Bench of this Court in the case of
TVL.Vitan Departmental Stores and Industries Limited Vs. The State of Tamil
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Nadu reported in (2014)45 GST95 (Madras) = MANU/TN/2266/2013 wherein an
identical issue like the one on hand arose and we are respectfully inclined to
follow the decisions of our High Court and we fully agree with the view taken in
the said decisions.
18. In the instant case also, as seen from the definition of “sale” as
defined under Section 2(p) of PGST Act, under Clause (iv) a transfer of the right
to use any goods for any purpose (whether or not for a specified period) for case,
deferred payment or other valuable consideration also comes within the meaning
of “sale”. Therefore, the contentions raised on behalf of the revision petitioner
herein, that the transfer of right to use granted in favour of M/s.Josco Footwear
Products, does not amount to sale under the provisions of the PGST Act is liable
to be rejected. Once the right in trademark is considered as goods and transfer of
right to use in the same is coming within the meaning of sale as defined under the
PGST Act, the same is bound to be subjected to tax under the provisions of the
PGST Act. Therefore, all the contentions raised in this regard by the learned
Senior Counsel appearing for the revision petitioner are liable to be rejected. With
this, the substantial questions of law No.1 is answered in negative.
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19. Then, coming to the contention of the learned Senior Counsel
appearing for the revision petitioner herein by placing reliance on the Notification
dated 10.12.1990 and that the same was in force notwithstanding introducing
Section 3A w.e.f. 01-04-1997 is concerned, even assuming that the same is in
force, any amount of exemption that was granted under the said Notification
would only cover within in scope all that liability that was cast on the dealer
concerned as on the date of Notification i.e. 10.12.1990 but not the liability that
may be fastened in future time to come. The liability that is now being cast upon
the revision petitioner is not one under any of the provisions of law that were
prevailing or existing as on 10.12.1990. But, it is only by virtue of the new
provision that was introduced under Section 3-A into the PGST Act w.e.f. 01-04-
1997, the impugned liability is being cast upon the revision petitioner herein.
Therefore, under no stretch of imagination, it can be said that the Notification
dated 10.12.1990 would automatically take into its purview the liability that was
created by virtue of the introduction of Section 3-A into the PGST Act with effect
from 01.04.1997. Therefore, any amount of reliance placed on the Notification
dated 10.12.1990 is of no avail to the revision petitioner. Further, it is also
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relevant to note that the Appellate Assistant Commissioner, dealt with this aspect
of the matter in his Order, dated 23-04-2007 at Paragraphs 4 to 11 by placing
reliance on the decisions of the Hon`ble Apex Court in the case of Sales Tax
Officer Vs. Darling Dairy Products reported in (1994) 94 STC 93 and State of
Bihar Vs. Krishna Kumar Kabra reported in (1998) 08 STC 1 which was also
confirmed by the Appellate Tribunal. We are in complete agreement with the said
reasoning. In so far as the contention basing on Notification, dated 16-10-2008
and contending that the Notification, dated 10-12-1990 was rescinded only on 16-
10-2008 is concerned, as is evident from the said Notification, dated 16-10-2008,
the same was issued consequent upon the Repeal of PGST Act, and the same was
general in nature rescinding all the notification issued under the said PGST Act.
Hence the said contention also liable to be rejected.
20. In the light of the above, the contention raised by the learned
Senior Counsel appearing for the revision petitioner by placing reliance on the
Notification dated 10.12.1990 is liable to be rejected.
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21. In the light of the above, all the substantial questions of law are
liable to be answered in negative and accordingly, the same are hereby answered
in negative.
22. In the result, this Tax Revision Petition is dismissed. No costs.
Consequently, connected miscellaneous petition is closed.
(Dr.A.S.M., J.) (M.S.K., J.)
29 .04.2026
NCC : Yes / No
Index : Yes / No
Internet : Yes / No
krk
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T.C.No.47 of 2011
To:
1.The Principal District Judge,
Sales Tax Appellate Tribunal,
Puducherry.
2.The Commercial Tax Officer (IAC)
Commercial Taxes Department
Puducherry
3.The Appellate Assistant Commissioner
Commercial Taxes Department
Puducherry
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T.C.No.47 of 2011
DR.JUSTICE ANITA SUMANTH
AND
MUMMINENI SUDHEER KUMAR, J.
krk
PRE-DELIVERY ORDER
IN
T.C.No.47 of 2011
29 .04.2026
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