Supplementary school coaching is not an educational institution service and is taxable as commercial training under GST.

Supplementary academic coaching for school students of Standards 5 to 12 does not qualify as a service supplied by an educational institution under Entry 66 of Notification No. 12/2017-Central Tax (Rate). The exemption applies only where the provider itself falls within the statutory definition of an educational institution, namely one providing pre-school, education up to higher secondary level, education forming part of a recognised curriculum, or approved vocational education. Because the activity was found to be extra tuition and coaching beyond regular school education, it falls outside that definition and is classifiable under Heading 9992 as commercial training and coaching services under Notification No. 11/2017-Central Tax (Rate), taxable at the prescribed GST rate.

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Issues: Whether academic coaching services provided to school students of Standards 5 to 12 are covered by the exemption for services supplied by an educational institution under Entry 66 of Notification No. 12/2017-Central Tax (Rate), or are taxable as commercial training and coaching services under Notification No. 11/2017-Central Tax (Rate).

Analysis: Entry 66 exempts only services supplied by an educational institution to its students, faculty and staff. An educational institution, for this purpose, is one providing pre-school education and education up to higher secondary school or equivalent, or education as part of a curriculum leading to a recognised qualification, or approved vocational education. The applicant's activity was found to be supplementary schooling and extra tuition for school students, which provides additional academic support beyond regular school education. Such activity does not itself constitute education up to higher secondary school or equivalent, nor education forming part of a recognised curriculum or approved vocational course. The service therefore does not satisfy the definition of an educational institution and cannot claim the exemption under Entry 66. The service was instead held to fall within Heading 9992 as education services, specifically commercial training and coaching services under Entry 30 and the corresponding classification entry 999293, taxable at 18% GST.

Conclusion: The exemption under Entry 66 was held inapplicable, and the coaching services were held taxable as commercial training and coaching services under the GST rate notification.

Final Conclusion: The ruling affirms that supplementary academic coaching for school students is not exempt as an educational institution service and is liable to GST at the prescribed rate for commercial coaching services.

Ratio Decidendi: Exemption for educational institution services applies only where the provider itself falls within the statutory definition of an educational institution, and supplementary tuition outside that definition is taxable under the relevant services classification.

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