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CESTAT determined that providing infrastructure and support services to educational institutions like IIM and XLRI does not constitute commercial training and coaching services subject to service tax. The appellants' role was limited to facilitating classes through infrastructure maintenance, marketing programs, and examination support, while the institutions maintained control over pedagogy, course design, and certification. Unlike typical coaching centers, appellants were integrated with degree-awarding institutions through revenue-sharing agreements. The tribunal held these were auxiliary educational support services qualifying for exemption, not commercial coaching services. The Commissioner's contradictory findings regarding service classification were rejected, and the appeal was allowed on grounds that infrastructure support to recognized educational institutions falls under exempt services.
CESTAT determined that providing infrastructure and support services to educational institutions like IIM and XLRI does not constitute commercial training and coaching services subject to service tax. The appellants' role was limited to facilitating classes through infrastructure maintenance, marketing programs, and examination support, while the institutions maintained control over pedagogy, course design, and certification. Unlike typical coaching centers, appellants were integrated with degree-awarding institutions through revenue-sharing agreements. The tribunal held these were auxiliary educational support services qualifying for exemption, not commercial coaching services. The Commissioner's contradictory findings regarding service classification were rejected, and the appeal was allowed on grounds that infrastructure support to recognized educational institutions falls under exempt services.
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