Aircraft type rating training not exempt as educational services where it only enables statutory examination eligibility.

Aircraft type rating training supplied under DGCA approval was not treated as education by an educational institution because the training did not itself culminate in a qualification recognised by law. The course completion certificate issued by the applicant was only a prerequisite for the statutory examination and did not carry legal recognition, while the DGCA separately conducted the examination and endorsed the aircraft rating. As the services were not part of a curriculum leading to a legally recognised qualification, entry 66(a) of Notification No. 12/2017-Central Tax (Rate) did not apply. The training services were therefore taxable and liable to GST.

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Issues: Whether the aircraft type rating training services supplied by the applicant were covered by entry 66(a) of Notification No. 12/2017-Central Tax (Rate) as services supplied by an educational institution to its students, faculty and staff.

Analysis: The exemption applies only if the supplier is an educational institution, meaning an institution providing education as part of a curriculum for obtaining a qualification recognised by law. The training in question was conducted under DGCA approval and the applicant issued course completion certificates, but the DGCA itself conducted the examination and separately endorsed the aircraft rating. The training therefore enabled the trainee to appear for the statutory process, but did not itself result in a qualification recognised by law. The course completion certificate was only a prerequisite document and did not have statutory recognition. The approved training was thus not shown to be education culminating in a legally recognised qualification.

Conclusion: The applicant was not an educational institution for this purpose, and the type rating training services were not exempt under entry 66(a). The services were liable to GST.

Final Conclusion: The ruling denies the claimed GST exemption and treats the impugned training services as taxable supplies.

Ratio Decidendi: Training that merely facilitates eligibility to sit for a statutory examination, while issuing only a course completion certificate, does not amount to education as part of a curriculum for obtaining a qualification recognised by law unless the training itself yields a legally recognised qualification.

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