The AAR ruled that the applicant, who coordinates on-the-job...

The AAR ruled that the applicant, who coordinates on-the-job training programs between universities and industry partners, acts as a "pure agent" under Rule 33 regarding stipend payments to trainees. The applicant functions merely as a conduit, receiving stipend amounts from industry partners and disbursing them in full to trainees without deductions. The AAR determined that the applicant satisfies all conditions of a pure agent, as it merely facilitates the payment process while the actual service is supplied by trainees to the industry partners. Consequently, the stipend amounts received by the applicant from industry partners and paid in full to trainees do not attract GST liability.

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