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of The HC held that the petitioners (universities) perform statutory and regulatory functions which are not commercial activities and therefore do not constitute a 'supply' in the course or furtherance of business under Section 7. Fees charged (affiliation, PG registration, admission, convocation and similar receipts) do not qualify as 'consideration' and ancillary activities incidental to education are not taxable. Entry No.66 of Notification No.12/2017-CT(R) covers the universities' services, and the impugned CBIC circulars are contrary to the statutory exemption and invalid. Consequently, the impugned show cause notice dated 10.10.2023 is quashed and the petitions are allowed.
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