Training fees charged by a society to member co-operative societies are taxable supply, with GST exemption for educational or government-financed institutions denied.

AAR Maharashtra held that coaching and training provided by a society to its member co-operative societies against annual fees is a supply of services for consideration and falls within business under GST, so the receipts are taxable. It further held that the educational services exemption was unavailable because the activity was not rendered to the institution's own students, faculty, or staff, and the compulsory contributions collected from member societies under the co-operative law did not amount to Government financing, direct or indirect. The claimed exemption for institutions wholly or substantially financed by the Government was therefore rejected, and GST was held applicable at the prevailing rate.

---

---

Issues: (i) Whether the applicant's coaching and training activity, for which annual fees are collected from member co-operative societies, constitutes a taxable supply of services under the GST law and falls within the concept of business; (ii) Whether the activity is exempt as educational services or on the footing that the institution is wholly or substantially financed by the Government.

Issue (i): Whether the applicant's coaching and training activity, for which annual fees are collected from member co-operative societies, constitutes a taxable supply of services under the GST law and falls within the concept of business.

Analysis: The applicant was found to be providing education and training to member societies against annual fees or contribution. Such service was treated as supply for consideration. The Authority held that provision by a society of facilities or benefits to its members for a subscription or other consideration is covered within business, and the training activity was in furtherance of business under the GST framework.

Conclusion: The activity was held to be a taxable supply of services and not a non-taxable arrangement.

Issue (ii): Whether the activity is exempt as educational services or on the footing that the institution is wholly or substantially financed by the Government.

Analysis: The Authority held that the applicant was not providing services to its own students, faculty, or staff, and therefore did not qualify for the educational institution exemption. It further held that the compulsory contributions collected from member societies under the State co-operative law did not amount to Government financing, direct or indirect. On that basis, the exemption available to institutions wholly or substantially financed by the Government was held inapplicable.

Conclusion: The claimed exemption was rejected and GST was held applicable at the prevailing rate.

Final Conclusion: The ruling determines that the applicant's training receipts are taxable supplies and do not enjoy the claimed GST exemption, so the applicant is liable to GST at applicable rates.

Ratio Decidendi: A society that supplies training services to its members for fees performs a taxable supply in the course of business, and mandatory contributions collected from member societies under a co-operative statute do not amount to Government financing for purposes of the educational exemption.

---