Training services exemption under GST fails where services are provided to an independent corporation, leaving consideration taxable.

Training services qualify for exemption under entry 72 of Notification No. 12/2017-Central Tax (Rate) only when they are provided to the Central Government, State Government or Union territory administration, and the prescribed government funding condition is met. Services rendered to Karnataka Skill Development Corporation did not satisfy that threshold because it is an independent legal entity distinct from the State Government, so the exemption was denied. Once the exemption was unavailable, the consideration received for implementation of the skill development programme remained a taxable supply of services under GST and was liable to tax.

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Issues: (i) Whether the applicant was entitled to exemption under entry No. 72 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 for training services provided through the Karnataka Skill Development Corporation. (ii) Whether the income earned from implementation of the skill development programme constituted taxable supply of services.

Issue (i): Whether the applicant was entitled to exemption under entry No. 72 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 for training services provided through the Karnataka Skill Development Corporation.

Analysis: The exemption under entry No. 72 applies only where services are provided to the Central Government, State Government or Union territory administration, the services are in the form of a training programme, and 75% or more of the total expenditure is borne by the specified government. The applicant's services were provided to Karnataka Skill Development Corporation, which is an independent legal entity distinct from the State Government. Since the first condition itself was not satisfied, the remaining conditions were not examined.

Conclusion: The applicant was not entitled to exemption under entry No. 72.

Issue (ii): Whether the income earned from implementation of the skill development programme constituted taxable supply of services.

Analysis: Once the claimed exemption was found inapplicable, the consideration received for the skill development services remained a supply for GST purposes and was liable to tax.

Conclusion: The income earned from the programme constituted a taxable supply of services.

Final Conclusion: The ruling denies exemption under the relevant notification and treats the consideration received for the skill development programme as liable to GST.

Ratio Decidendi: An exemption for training services under the notification is available only when the services are actually provided to the specified government authority and the prescribed funding condition is satisfied; services rendered to an independent corporation do not qualify merely because the programme is government-linked.

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