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Issues: (i) Whether training services provided by an MSDE/NSDC affiliated training partner conducting NSQF-aligned digital marketing courses are exempt from GST under Sl. No. 69 of Notification No. 12/2017-Central Tax (Rate); (ii) whether the amendment omitting NSDC-approved training partners and the subsequent circular permit exemption for the intervening period from 10.10.2024 to 15.01.2025.
Issue (i): Whether training services provided by an MSDE/NSDC affiliated training partner conducting NSQF-aligned digital marketing courses are exempt from GST under Sl. No. 69 of Notification No. 12/2017-Central Tax (Rate).
Analysis: The entry grants exemption to services provided by a training partner approved by the National Skill Development Corporation or the Sector Skill Council, when the services are in relation to the National Skill Development Programme, a vocational skill development course under the National Skill Certification and Monetary Reward Scheme, or any other scheme implemented by NSDC. The applicant was found to be an NSDC-approved training partner, and the digital marketing course was accredited by NSDC and mapped to the relevant skill framework. The services were treated as falling within the exempt entry.
Conclusion: The services were exempt from GST under Sl. No. 69 of Notification No. 12/2017-Central Tax (Rate).
Issue (ii): Whether the amendment omitting NSDC-approved training partners and the subsequent circular permit exemption for the intervening period from 10.10.2024 to 15.01.2025.
Analysis: The amended entry temporarily removed the express reference to training partners approved by NSDC and restricted the exemption to training bodies accredited with an awarding body recognised by NCVET. The later notification restored the NSDC route from 16.01.2025. The circular then regularized GST payment for the intervening period on an "as is where is" basis, meaning the past position would stand as regularized according to whether tax had been paid or not.
Conclusion: No exemption was available for the intervening period, but the liability for that period stood regularized on an "as is where is" basis.
Final Conclusion: The applicant's training services were held exempt generally, while the temporary withdrawal period was separately dealt with through regularization under the circular, resulting in only partial relief for that interval.