Industry partner reimbursement to YAS students not subject to GST

The ruling concluded that the reimbursement of the stipend paid to students by the industry partner to Yashaswi Academy for Skills (YAS) does not attract GST. The questions regarding the reimbursement of insurance premium and expenses for uniform and safety shoes were withdrawn by the applicant during the proceedings, and no ruling was provided on these issues.

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Issues Involved:
1. Whether the reimbursement by Industry Partner to YAS of the stipend paid to students attracts GSTRs.
2. Whether the reimbursement by Industry Partner to YAS of the insurance premium attracts GSTRs.
3. Whether the reimbursement by Industry Partner to YAS of the expenses for uniform and safety shoes attracts GSTRs.

Detailed Analysis:

1. Reimbursement of Stipend Paid to Students:
The applicant, Yashaswi Academy for Skills (YAS), acts as an intermediary under the National Employability Enhancement Mission (NEEM) scheme, facilitating on-the-job training for students by partnering with various industry partners. YAS is responsible for preparing attendance records, processing, and disbursing stipends, providing uniforms and safety shoes, and taking insurance policies for trainees. The industry partners reimburse YAS for these expenses.

The core issue is whether the reimbursement of the stipend paid to students by the industry partner attracts GST. The applicant contends that they act as a "pure agent" as defined under Rule 33 of the CGST Act. They do not retain any part of the stipend and merely facilitate its transfer from the industry partner to the trainees. The jurisdictional officer concurs, noting that YAS is merely a conduit, and the actual service is provided by the trainees to the industry partners.

The ruling concludes that the reimbursement of the stipend by the industry partner to YAS does not attract GST because YAS is acting as an intermediary, and the entire amount received as stipend is paid to the trainees without any deductions.

2. Reimbursement of Insurance Premium:
The applicant initially sought a ruling on whether the reimbursement of the insurance premium paid by YAS attracts GST. However, this question was withdrawn by the applicant during the proceedings. Therefore, no ruling was provided on this issue.

3. Reimbursement of Expenses for Uniform and Safety Shoes:
Similarly, the applicant also withdrew the question regarding the reimbursement of expenses for uniforms and safety shoes. Consequently, no ruling was issued for this question either.

Conclusion:
The ruling specifically addresses the first issue, determining that the reimbursement by the industry partner to YAS of the stipend paid to students does not attract GST. The other two issues were not addressed as the applicant withdrew these questions during the proceedings.

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