Specific exemption entry for IIMs prevails, and the general education exemption cannot be selectively used for GST relief.

For Indian Institutes of Management, the specific exemption entry in Notification No. 12/2017-Central Tax (Rate) governs taxable treatment, and the general exemption for educational institution services cannot be selectively invoked to broaden exemption. Applying this structure, the AAR held that long-duration postgraduate diploma and degree programmes at IIM Bengaluru, other than those expressly covered by the specific entry, are not exempt under the general education exemption. The same reasoning applied to online educational journals or periodicals supplied to the institute, which also could not claim exemption under the general entry. The ruling therefore denied GST exemption on both issues.

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Issues: (i) Whether the long duration post graduate diploma and degree programmes offered by the Indian Institute of Management, Bengaluru, other than those specifically covered in Serial No. 67 of Notification No. 12/2017-Central Tax (Rate), are exempt as education provided as part of a curriculum for obtaining a qualification recognised by law; (ii) Whether supply of online educational journals or periodicals to the Indian Institute of Management, Bengaluru is exempt from GST under Serial No. 66 of Notification No. 12/2017-Central Tax (Rate).

Issue (i): Whether the long duration post graduate diploma and degree programmes offered by the Indian Institute of Management, Bengaluru, other than those specifically covered in Serial No. 67 of Notification No. 12/2017-Central Tax (Rate), are exempt as education provided as part of a curriculum for obtaining a qualification recognised by law.

Analysis: Serial No. 66 is a general exemption for services by an educational institution, while Serial No. 67 is a specific carve-out for services provided by Indian Institutes of Management. Both entries operate under the same heading, but the notification structure shows that IIMs have been separately identified for special treatment. Once a specific entry is provided for IIMs, selective reliance on the general entry for some programmes and the specific entry for others is not permissible. The change in the statutory character of the institute under the Indian Institute of Management Act, 2017 does not alter the scope of the exemption notification in the manner suggested by the applicant.

Conclusion: The claim to exemption under Serial No. 66 was rejected. The answer to issue (i) is in the negative and is against the assessee.

Issue (ii): Whether supply of online educational journals or periodicals to the Indian Institute of Management, Bengaluru is exempt from GST under Serial No. 66 of Notification No. 12/2017-Central Tax (Rate).

Analysis: The second question also depended on applying the general entry in Serial No. 66 despite the presence of the specific entry for Indian Institutes of Management in Serial No. 67. For the same structural reason, the general exemption could not be invoked for the institute where the notification had carved out a separate treatment for IIMs.

Conclusion: The answer to issue (ii) was also in the negative and is against the assessee.

Final Conclusion: The ruling holds that, for Indian Institutes of Management, the specific exemption entry alone governs the educational services covered by the notification, and the general educational institution exemption cannot be selectively invoked to extend exemption beyond that specific entry.

Ratio Decidendi: Where a notification contains a specific exemption entry for a class of institutions, that specific entry governs their taxable treatment and the general exemption entry cannot be selectively applied to expand the scope of exemption.

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