Service tax exemption for education-linked services upheld where course affiliation and recognised degree requirements were satisfied.

Services connected with an educational institution were held eligible for service tax exemption where they formed an essential part of a course or curriculum leading to a certificate, diploma, degree or other qualification recognised by law. The respondent's one-time affiliation to Jawaharlal Nehru Technological University and the fact that the degree awarded was recognised by the UGC supported satisfaction of the exemption conditions. The appellate authority's factual finding that the notification requirements were met was accepted, and no infirmity was found in that conclusion. The Revenue's challenge therefore failed.

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Issues: Whether the respondent was entitled to exemption from service tax under the relevant exemption notification in respect of services connected with an educational institution leading to a recognised degree or qualification.

Analysis: The dispute turned on whether the services fell within the exemption meant for taxable services provided to a commercial coaching or training centre when such services form an essential part of a course or curriculum of another institute or establishment leading to a certificate, diploma, degree or other educational qualification recognised by law. The respondent had obtained one-time affiliation to Jawaharlal Nehru Technological University and the degree issued was recognised by the UGC. The appellate authority had already examined the facts and concluded that the respondent satisfied the conditions of the exemption notification, and no infirmity was found in that conclusion.

Conclusion: The respondent was eligible for the service tax exemption, and the Revenue's challenge failed.

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