Licensing of digital platform access is not education service and is classifiable as a licensing supply under GST.

A non-exclusive user licence to access a proprietary digital learning platform was held not to be an education service under Heading 9992 because the supplier did not itself impart education or assume instructional responsibility; the supply was characterised by access to digital content rather than direct teaching. As the supply was not classifiable as education service, exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) was denied, with the notification applied strictly and not extended beyond its express scope. The transaction was instead treated as a licensing service more appropriately classifiable under Heading 9973, specifically SAC 997331.

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Issues: (i) Whether supply of Coursera User License to OSDA is classifiable under Heading 9992 as education service; (ii) Whether exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017 is available; (iii) Whether the supply is more appropriately classifiable under Heading 9973.

Issue (i): Whether supply of Coursera User License to OSDA is classifiable under Heading 9992 as education service.

Analysis: The supply consisted of a user licence granting access to Coursera's proprietary digital platform. The Applicant did not itself impart education, conduct training, or assume instructional responsibility. The content was hosted by Coursera and accessed by students through the licence arrangement. The relevant classification depends on the dominant character of the supply, and a right of access to digital content is not, by itself, a service of imparting education.

Conclusion: The supply is not classifiable under Heading 9992 as education service.

Issue (ii): Whether exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017 is available.

Analysis: The exemption was considered unavailable because the supply was not classified under Heading 9992. The recipient was an autonomous society and not the State Government. The arrangement was for access to online content through a licence, not a direct training programme supplied within the strict scope of the notification. Exemption notifications are construed strictly and cannot be expanded beyond their terms.

Conclusion: The exemption under Sl. No. 72 is not available.

Issue (iii): Whether the supply is more appropriately classifiable under Heading 9973.

Analysis: The transaction was found to be a grant of a non-exclusive right to access Coursera's platform, which is more accurately treated as a licensing service. The specific description of licensing services under Heading 9973 was held to be more apt than the residual heading for online content services. The classification under Heading 9973 was also consistent with the commercial arrangement and the manner in which invoices were raised.

Conclusion: The supply is more appropriately classifiable under Heading 9973, specifically SAC 997331.

Final Conclusion: The ruling answers the reference against classification as education service, denies the claimed exemption, and accepts licensing-based classification under Heading 9973 for GST purposes.

Ratio Decidendi: A service consisting of a non-exclusive licence to access a proprietary digital platform is classified by its specific licensing character rather than as education service or residual online content, and exemption notifications must be applied strictly within their express terms.

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