Applicability of GST exemption under Entry 66(a) to clinical postings provided by a specialised hospital/educational institution to students of another educational institution

[Mith Moh]

ABC is a specialised oncology hospital and educational institution for certain recognised courses and is affiliated/recognised by university and bodies such as NBEMS and NMC.

Students enrolled in recognised PG/medical programmes are required, as part of their prescribed curriculum, to undergo a mandatory clinical posting of in an oncology centre. The respective colleges/universities send their students to ABC.

ABC provides the required clinical exposure, access to its oncology facilities and related training. The consideration for the posting may be paid either by the concerned college/institution or by the student.

Question: Whether the fees collected by the Applicant for such mandatory clinical postings are exempt under Sl. No. 66(a) of Notification No. 12/2017-Central Tax (Rate) as "services provided by an educational institution to its students, faculty and staff", considering that:

1. the clinical posting is a mandatory component of a curriculum leading to a qualification recognised by law under paragraph 2(y)(ii) of the Notification;
2. the Applicant is itself an educational institution/recognised oncology institution for certain courses, but the students undertaking the posting are primarily enrolled with another University/college; and
3. the Applicant is providing only the specific clinical component required under the students' recognised curriculum, rather than conducting the entire degree/PG programme.

Does the expression "to its students" in Sl. No. 66(a) require the students to be formally enrolled with the Applicant, or can students placed with the Applicant for a mandatory component of their recognised curriculum be regarded as receiving educational services from the Applicant for purposes of the exemption?

Please refer ADVANCE RULING No. KER/17/2025 Dated 01.07.2025 which held that 102 government approved courses being part of Four Year Undergraduate Program is covered under Sl. No. 66(a) of Notification No. 12/2017-Central Tax (Rate)

AI Summary

GST exemption for clinical postings depends on recognised curriculum status and a formal educational relationship with posted students.
GST exemption for mandatory clinical postings requires that the training form part of a legally recognised curriculum and be provided by an educational institution to its students. The exemption is supportable where the clinical training centre is formally approved within the academic framework, students are officially posted, attached or registered for the component, and structured supervision, attendance and assessment are provided. Mere clinical exposure to students enrolled elsewhere, without a formal academic or regulatory relationship, creates significant litigation risk. Supporting records include curriculum requirements, approvals, affiliations, posting orders, and training records.