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"65. (47) "franchise" means an agreement by which the franchisee is granted representational right to sell or manufacture goods or to provide service or undertake any process identified with franchisor whether or not a trade mark, service mark, trade name or logo or any such symbol, as the case may be, is involved;
(48) "franchisor" means any person who enters into franchise with a franchisee and includes any associate of franchisor or a person designated by the franchisor to enter into franchise on his behalf and the term "franchisee" shall be construed accordingly;
(105) "taxable service" means any service provided or to be provided, (zze) to a franchisee, by the franchisor in relation to franchise;"

26. We find that the definition of "Franchise" as above involves trademark, service mark, trade name or logo (or any such symbol);

learned Counsel for the appellants submits that the expression "any 41 ST/51954/2015 ST/60765/2019 such symbol" should be read with the preceding words and should not be extended beyond. We are in agreement with the same following the principal of ejusdem generis, we find that the name of the university being used by LCs/ RCs cannot be taken to be a trademark, service mark, trade name or logo (or any such symbol). A reading of the MOU does not give an understanding that it is Franchise Agreement. We find force in the argument of the learned Counsel for the appellants that even if it is a Franchise Service, it would be exempt in terms of the Notification discussed above as they are rendered in relation to education.

6. We have perused the order impugned in this appeal. The order under appeal is rendered by the CESTAT and it was aware of the definition of the term "franchise service" as appearing in Section 65(47) of the Finance Act, 1994. First, the definition of the term "franchise" as found in this clause means an agreement by which the franchisee is granted representational right to sell or manufacture goods or to provide service or undertake any process identified with franchisor, whether or not a trade mark, service mark, trade name or logo or any such symbol, as the case may be, is involved. Insofar as the understanding of the Revenue about the "franchise service" is concerned, it is apparent that this is to be found in sub-clause (zze) of clause (105) of Section 65 of the Finance Act, 1994. There, the definition of "taxable service" means any service provided or to be provided and, in the instant case, to a franchise by the franchisor in relation to franchise.