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    <description>One-to-one online tutoring and customised instruction to school students did not qualify as exempt services under Serial No. 66(a) of Notification No. 12/2017-Central Tax (Rate) because the provider was not an educational institution. The exemption applies only to services supplied by an educational institution to its students, faculty or staff, and an educational institution must provide pre-school education, education up to higher secondary level or equivalent, recognised curriculum education, or approved vocational training. Special tutoring and coaching to students already enrolled in schools was treated as commercial training and coaching under Heading 9992, and the activity was not shown to form part of a recognised qualification or approved vocational course.</description>
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