Prospective exemption withdrawal for computer training means earlier exemption remained available; retrospective exclusion was not permitted.

Computer training services fell within the exemption notifications for the relevant period because the original notification covered computer training institutes. The later amendment excluding computer training institutes operated only from 16.06.2005 and could not be applied retrospectively. On that basis, the tax demand was not sustainable and the exemption benefit remained available for the prior period.

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Issues: Whether computer training services were covered by the exemption notifications for the relevant period and whether the later amendment excluding computer training could operate retrospectively.

Analysis: The exemption notifications initially covered computer training institutes, and the benefit was available for the relevant period. The later notification amending the exemption to exclude computer training institutes took effect only from 16.06.2005. The amendment could not be given retrospective effect. Following the earlier Tribunal view that computer training fell within the exempted category for the relevant period, the tax demand was not sustainable.

Conclusion: The issue is decided in favour of the assessee. Computer training services were exempt for the relevant period, and the amendment excluding such services was prospective only.

Ratio Decidendi: An exemption withdrawal or exclusion introduced by amendment operates prospectively unless the notification expressly provides otherwise, and computer training may fall within vocational training for the period when the exemption text so covered it.

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