The AAR held that the applicant is ineligible for exemption...

The AAR held that the applicant is ineligible for exemption under serial no. 66(b)(i) & (ii) of notification No. 12/2017-CT (Rate) for transportation and catering services provided directly to students, as the consideration was received from students and not from the educational institution. Consequently, the services are not deemed to be provided to the school, failing the primary condition for exemption. The authority further declined to address the question of refund of tax paid on such services in earlier years, as it falls outside the scope of subsection 97(2). Therefore, the applicant cannot claim exemption or refund under the specified notification for the impugned services.