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The AAR held that fees collected from medical officers for Leave Without Allowance do not constitute taxable supply under GST. Such fees arise from employer-employee relationships governed by service rules and serve as administrative deterrent measures rather than consideration for services rendered. No contractual obligation exists to provide goods or services, making these collections non-taxable under Section 7 of CGST Act 2017. Conversely, inspection fees collected from self-financing medical institutions for facility assessments and issuing NOCs/ECs constitute taxable supply at 18% GST. These regulatory services enable commercial educational operations and fall under SAC 999799 rather than education services, attracting standard GST rates per notification 11/2017-Central Tax.
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