Services for Degree Courses by Applicant Exempt from Central & Karnataka GST

The ruling authority found that the services provided by the applicant in affiliation with universities for degree courses are exempt from both Central Goods and Services Tax and Karnataka Goods and Services Tax under entry no. 66 of the respective notifications. This exemption applies as the courses lead to recognized qualifications and are conducted in affiliation with universities, meeting the criteria for exemption as an educational institution.

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Issues involved:
1. Interpretation of exemption under entry no. 66 of Notification No. 12/2017 - Central Tax dated 28.06.2017 for educational services provided by an institution in affiliation with universities.
2. Determination of whether services provided by the applicant in affiliation with specified universities for degree courses are exempt from Goods and Services Tax.

Analysis:

Issue 1: Interpretation of exemption under entry no. 66 of Notification No. 12/2017 - Central Tax

The applicant, a private limited company, sought an advance ruling on whether the services provided in affiliation with universities for degree courses are exempt from GST under entry no. 66 of the Notification No. 12/2017 - Central Tax. The applicant's contention was that by affiliating with a university and imparting education as per the university's curriculum, they qualify as an educational institution providing services leading to qualifications recognized by law. The ruling authority analyzed the definition of "educational institution" under the notification, which includes education as part of a curriculum for obtaining a recognized qualification. Since the applicant's courses lead to qualifications recognized by law and are conducted in affiliation with universities, they are considered an educational institution eligible for the exemption.

Issue 2: Determination of GST exemption for services provided by the applicant

The ruling authority examined the specific services provided by the applicant in affiliation with universities for degree courses. They referenced the entry no. 66 of Notification No. 12/2017 - Central Tax, which exempts services provided by an educational institution to its students, faculty, and staff. Since the applicant's services meet the criteria of being part of a curriculum leading to recognized qualifications and are conducted in affiliation with universities, they are deemed to be exempt from Central Goods and Services Tax. The ruling also extended this exemption to Karnataka Goods and Services Tax, as a similar provision exists under the state tax regulations.

In conclusion, the ruling authority determined that the services provided by the applicant in affiliation with universities for degree courses are exempt from both Central Goods and Services Tax and Karnataka Goods and Services Tax under entry no. 66 of the respective notifications, subject to the condition that the education services must be part of a curriculum leading to recognized qualifications.

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