Recognised educational qualifications cover statutory professional-course stages, exempting CA-CPT, ICWA-Foundation and Intermediate coaching from service tax.

Coaching for CA-CPT, ICWA-Foundation and Intermediate (10+2) examinations falls within the service tax exemption for training leading to an educational qualification recognised by law. The exemption is not limited to final-stage qualifications: CA-CPT and ICWA-Foundation are compulsory statutory stages required for progression in their respective professional courses, while Intermediate coaching leads to a recognised educational qualification. The notification does not require a fee cap or separate affiliation, and identical treatment in subsequent periods supports consistent application. The coaching is therefore exempt under Notification No. 33/2011-S.T.

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Issues: Whether coaching for CA-CPT, ICWA-Foundation and Intermediate (10+2) examinations qualifies for exemption as coaching leading to an educational qualification recognised by law under Notification No. 33/2011-S.T. dated 25.04.2011.

Analysis: The exemption applies to coaching or training leading to a certificate, diploma, degree or educational qualification recognised by law, without confining its benefit to a final-stage qualification. CA-CPT is a compulsory first stage of the statutory CA course governed by the Chartered Accountants Act, 1949 and its regulations, since successful completion is necessary for progression to IPCC. ICWA-Foundation is likewise a prescribed statutory stage of the professional course. Intermediate coaching leads to a recognised educational qualification. The notification cannot be restricted by importing conditions that the qualification must be final, that fees must remain within a prescribed limit, or that affiliation must be separately established. The Revenue's prior acceptance of exemption for identical coaching in subsequent periods, absent any change in facts or law, also militates against an inconsistent fiscal position.

Conclusion: Coaching imparted for CA-CPT, ICWA-Foundation and Intermediate (10+2) examinations is exempt from service tax under Notification No. 33/2011-S.T. dated 25.04.2011.

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