Online coaching is commercial training, not OIDAR; Rajasthan place-of-supply rules make the supply intra-State.

Digitally delivered coaching for competitive examinations remained commercial training and coaching because the live classes, recorded lectures, mentoring, doubt-clearing sessions, tests, and study material showed instructor-led training; the platform was only the mode of delivery, so the service did not fall within OIDAR. For place of supply, the specific rule for training services applied, and because the supplier's operations and the place of supply were both in Rajasthan, the supply was treated as intra-State despite students being outside the State. The tax liability was therefore CGST and Rajasthan SGST, not IGST.

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Issues: (i) Whether online training services delivered through live or recorded digital platforms are classifiable as Online Information and Database Access or Retrieval Services or as Commercial Training and Coaching Services; (ii) whether the tax liability on such supplies made to unregistered students outside Rajasthan is to be discharged as IGST or as CGST and SGST.

Issue (i): Whether online training services delivered through live or recorded digital platforms are classifiable as Online Information and Database Access or Retrieval Services or as Commercial Training and Coaching Services.

Analysis: The service supplied by the applicant was found to be structured coaching for competitive examinations, supported by live classes, recorded lectures, doubt-clearing sessions, mentoring, performance evaluation, mock tests, and dispatch of study material. The digital platform was treated only as the medium of delivery and not as the essential character of the supply. The nature of the service was therefore held to be commercial training and coaching, not a technology-driven retrieval of digital content within the OIDAR category.

Conclusion: The service is classifiable under Commercial Training and Coaching Services and not under OIDAR.

Issue (ii): Whether the tax liability on such supplies made to unregistered students outside Rajasthan is to be discharged as IGST or as CGST and SGST.

Analysis: Once the supply was held to be commercial training and coaching, the place of supply was governed by the specific rule for training services. The applicant's operations, including faculty, content development, billing, platform management, and dispatch of study material, were located in Rajasthan. As the location of the supplier and the place of supply were both in Rajasthan, the supply was treated as intra-State, irrespective of the student's location.

Conclusion: The tax liability is CGST and Rajasthan SGST and not IGST.

Final Conclusion: The ruling holds that the applicant's online coaching model remains a training and coaching supply with place of supply in Rajasthan, so transactions to unregistered students outside the State do not alter the intra-State tax character of the supply.

Ratio Decidendi: A digitally delivered coaching programme does not become OIDAR merely because it is accessed online; where the substance of the service is instructor-led training, the specific place-of-supply rule for training applies and the supply is intra-State if both supplier location and place of supply are in the same State.

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