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    <title>2025 (12) TMI 764 - CESTAT CHANDIGARH</title>
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    <description>A commercial arrangement amounts to franchise service only where the recipient is granted a representational right and loses its independent identity by representing the franchisor to outsiders. On the stated facts, the agreement was only a licence to use intellectual property for production, sale, distribution and marketing, while the recipient retained business autonomy and marketing control. The licensors did not exercise the level of control associated with a franchise. The services were therefore treated as intellectual property service, and the exemption linked to payment of research and development cess was available, so the demand could not be sustained.</description>
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