TaxTMI 
TaxTMI 
2019 (7) TMI 1195
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....nd Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 in totality. ii. Whether the applicant, a Charitable Society having the main object and factually engaged in imparting Medical Education, satisfying all the criteria of "Educational Institution" is liable for registration under the provisions of section 22 of the Central Goods and Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 or it can remain outside the preview of registration in view of the provisions of section 23 of the said act as there is no Taxable supply. iii. In a situation if above questions are answered against the contention of the applicant institution then following further questions are being raised for the kind consideration by the Honourable Bench. a. Whether the fees and other charges received from students and recoupment charges received from patients (who is an essential clinical material for education laboratory) would constitute as "outward supply" as defined in section 2 (83) of The Central Goods and Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 and if yes then whether it will fall in classification entry at Sr. N....
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....nt features, that are needed to be considered with reference to the status of Applicant Society, where its main activity of Medical Education is substantially funded by the Government as a joint venture and then to decide whether the said Society can be brought within the ambit of the provisions of the CGST/MGST Act, particularly when there is no business activity carried out by the society. The related salient features are as under. a. Background of the Society vis-a`-vis the purpose of existence. i. The constitution of India had promised implementation of effective health delivery system to the rural masses in general & those unprivileged in particular. Govt. of India had setup several Committees (Working Groups) with the task of finding out the practical modalities addressing the said issue in general & the reason for utter failure of Govt., in attracting qualified & trained Doctors for going & settling down in rural areas. ii. One of the solutions recommended was to establish an innovative medical institution in rural area, which would set forth the required modalities for training the Doctors, who would not only develop an aptitude but also a capacity to u....
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....oth levels, i.e., before and after graduation is being monitored and regulated by the different Universities under the broader umbrella of Medical Council of India (Here-in-after referred to as "MCI"). These Universities have laid down the detailed academic syllabus for Graduation and Post-Graduation studies through Statutes and every College is obliged to get affiliated with the concerned University in whose jurisdiction the said College falls. Besides academic syllabus, the standard and quality of imparting the medical education is also regulated by Medical Council of India. In absence of recognition by such regulators no medical personnel passing from such Medical College can practice in the field of medicine. vii. For grant of recognition, these regulators carry out inspection of the teaching facilities at College, on periodic basis and that too on subject to subject basis. For that matter, regulators have laid down norms specifying the floor area required for in housing teaching assignment, practical training for undertaking the operations, strength of teachers/nursing staff, their required academic qualifications/experience, requirements of teaching aids like equipme....
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....to Heart, Lung, Bones, Blood, Nerve, Gastro etc. caused by several reasons including infections through insects, bacterial, viral etc. to be essentially made available to the students and teacher for getting them educated with the wide spectrum having a focus on advanced mechanised diagnosis, management of drugs, rehabilitation but at an affordable cost. These varied essential clinical materials, can be made available only by admitting the persons suffering from these various diseases, in the teaching lab, carryout Investigations, laboratory tests, X-rays, Citi Scan for diagnosing the diseases in more precise way and for that purpose, MGIMS is maintaining and managing 1000 Beds for imparting the theoretical and practical bedside Medical Education. Such teaching labs accommodating the stipulated teaching beds in which the persons suffering from these various diseases is admitted is known as "Kasturba Hospital". The said teaching lab is an integrated part in imparting systematic medical education like other labs in other branches of education. Thus "Kasturba Hospital" is not an independent establishment in isolation or a Hospital rendering healthcare services only since it is a teach....
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....nstrumentality of the State within the meaning of Article-12 of the Constitution of India vide Judgment of the Hon'ble High Court of Judicature at Bombay, Nagpur Bench in the case of Ajay Gambhir (cited above)". Thus, the status of Kasturba Health Society as held by Judicial Forum is a "State". c. No activity being undertaken involving any profit motive neither carries on any business. i. Applicant Society is engaged in imparting the systematic education and training as per the syllabus stipulated by concern competent Authorities where MGIMS is the major activity of APPLICANT SOCIETY without having any profit motive or pre-designed factor of monetary gain and as such cannot be assumed to have engaged in carrying on any business. The scale of expenditure for running of MGIMS that is incurred for imparting the Education at affordable cost, runs over the Fees and charges recovered from Students and Patients. Substantial portion thereof is borne by Central and State Govt. This contention will be evident from the tabulated figures as under of last three years - Particulars FY 2015-16 FY 2016-17 FY 2017-18 Direct expenditure of Running of MGIMS 116,32....
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....uirement of the material inputs are exhibited electronically at different designated collecting points. No person from outside can collect any medicine or any other item from such storage. Thus, whatever amount is collected at different collection centres within the college premises is nothing but recovery of Hospital Charges in instalments against issuance of receipts which does not amount to a realisation of sale proceeds for goods or services. Needless to mention that this process is modality to recovery the Hospital Charges at different points, different times for different heads for different inputs necessitated for investigation, diagnosis, medical treatments, surgical or procedures and that too keeping in mind the sole purpose of Convenience of Patient. iv. In order to maintain the teaching lab -The following activities are carried out are as under; a. The clinical materials (patients) are examined and the reasons, causes, symptoms and history of the sufferings is jotted down and making comparative thereof is done in OPD which is further supported by the pathological or microbiological or radiology investigations, and if necessary further investigation on h....
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....for urban population Rs. 500/- for entire year for a family of five members. As a result, presently more than 10 Lakh individuals are taking the benefit of subsidised cost of medical treatment. e. In order to retain the inflow of sufficient clinical material for the purpose of medical education, the Society was already charging concessional rates for investigations, treatment and cost of medicines [Here-in-after referred as recoupment charges]. Further the teachers (Doctors) were empowered to waive partly or fully such recoupment charges towards consumed medicines and other items. Meanwhile, the Charity Commissioner by enforcing the provisions of Sec.41D of B.P.T. Act, 1950 made mandatory to administer the medical treatment free of cost to 10% of the intake capacity. Subsequently State & Central Govt. have stipulated to provide medical treatment at concessional rate to the patients falling within "BPL" category. f. RESEARCH WORK PURSUED Beside practical work on field the teachers and students are propagating their findings through Seminars, Workshops etc. & thus many countries having taken cognizance of the said research invited them in various workshops,....
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.... consigner and consignee both, in order to continue uninterrupted movement of Goods. Further the suppliers, Vendors and Service Providers from all the corners were pressurising to provide them the GST Registration Number of the Applicant Institution. In this scenario the society without having the GST registration No. was facing the difficulties and in order to overcome these issues, has applied for voluntary registration and as a result got registered with GSTN having registration No. 27AAATK2046G1ZV with effect from 21st July 2017. The copy of registration certificate and application is annexed herewith. iii. Though the applicant society got registered voluntarily under GST for the reasons mentioned above, it has not filed any returns since none of the activity was in the nature of "business" so as to fall within the meaning of "supply" as provided in section 2(87) of the GST Act and hence it is believed in bona fide that it is not obliged to comply with the provisions of GST Act. iv. However the jurisdictional GST authorities have issued one after another notices to the applicant society for adhering to the compliance with an obligation of filing of returns & t....
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....s an independent intention to carry on business in the incidental or ancillary activity is established. c. These disputes were also settled by the courts on factual position having similar background with no contrary view in following cases:- • Apex court in case of Sai Publication Fund 4 SCC 7 (SC) = 2002 (3) TMI 45 - SUPREME COURT - decided that in respect of sale of books, booklets, pamphlets, photos, stickers and other publications containing message of Saibaba and the turnover of such publication cannot be assessed to sales tax under the BST Act, on the facts & in the circumstances of the present case irrespective of the profit motive, it could not be said that the Trust either was a "dealer" or was carrying on trade, commerce etc. The Trust is not carrying on trade, commerce etc., in the sense of occupation to be a "dealer" as its main object is to spread message of Saibaba of Shiridi. • In case of Indian Institute of Technology v. State of U.P. [(1976) 38 STC 428 - Allahabad HC = 1974 (2) TMI 72 - ALLAHABAD HIGH COURT - observed that the statutory obligation of maintenance of the hostel which involved supply and sale of food wa....
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....ble Commissioner of Sales Tax in specific cases having regard to the nature of activities in favour of the Trust which are discussed in later part of the submission. III. Under the Service Tax Regime. [Operated simultaneously with Sales Tax and VAT Regime for levy of Tax on Services] The Finance Act 1994, also attempted to cover various services provided by the Charitable Institution those having commercial sense within its ambit and levied the Service Tax on the services rendered by them primarily on the value of consideration. However, while levying tax the Services beyond the scope of Business or commercial nature are excluded and even those having flavour of commercial activities are also excluded to the larger extent by providing specific exemptions like those having registration U/S 12AA of the Income tax Act 1961. IV. Under the GST Regime. a. Even the GST Act is also not making any departure from the basic concept where the activity of Charitable Institution having the flavour of business is proposed to be taxed which is evident from the scope of Section 2(17) of The CGST Act defining "'Business" that gives the context to the above-men....
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....ify as 'supply' for the levy of tax. In this reference the meaning of word "Business" & further meaning of phrase in the course of business and in furtherance of business is needed to be looked into. i. Section 2(17) of the CGST Act, 2017 Defines "business" as under. "Business" includes a. Any trade, commerce, manufacture, profession, vocation, adventure, wager or any other similar activity, whether or not it is for a pecuniary benefit: b. An activity or transaction in connection with or incidental or ancillary in sub-clause (a); c. any activity or transaction in the nature of sub-clause (a), whether or not there is volume, frequency, continuity or regularity of such transaction; d. Supply or acquisition of goods including capital goods and sends in connection with commencement or closure of business; e. Provision by a club, association, society, or any such body (for a subscription or any other consideration) of the facilities or benefits to its members; f. Admission, for a consideration, of persons to any premises; g. Services supplied by a person as the holder of an office which has....
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....encounter the character of the phrase "in the course of or furtherance of business". Still the same is needed to be understood in common parlance. The phrase 'In the course of or furtherance of' is used in Section 2(17), in the context of defining 'Business', section 2(83) defining Outward Supply and section 17 of the CGST Act defining the scope of supply. This definition gives context to the abovementioned term just like in any value-added taxation system, even in the case of GST Law, the effective tax to be paid is always on business transaction only. Therefore, it is very clear, that only commercial transactions are taxable. If any activity whether made or agreed to be made is neither for continuity of business nor for advancing/furtherance of the same, such a transaction, will not be a supply at all. Further Section 16(1) in the context of eligibility of Input Tax credit again use the said the term which essentially signifies continuity in relation to a specified activity, whereas "in furtherance or' means anything done which assists or advances a particular act. Therefore, in simple words, the phrase "in the course of or furtherance of business" means ....
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....ps situated within the premises of a religious place are rented out, income from letting out of such property is wholly exempt from GST. But if such properties are not situated in the precincts of a religious place meaning thereby not within walls or boundary walls of the religious place, income from such letting out will lose this exemption and income from it will be liable to GST. Income from a religious ceremony organized by a charitable trust is exempt as per the above notification. So, the income from Navratri functions, other religious functions, and religious poojas conducted on special occasions like religious festivals by persons so authorized for this purpose by the charitable or religious trust are exempt from GST. But a careful perusal of this exemption shows that all income from such a religious ceremony is not exempt. Therefore, the nature of income is an essential factor for ascertaining whether it will be taxable or exempt. If income loses its religious nature, it is definitely chargeable to GST. For example, if with regard to Ganesh utsav or other religious functions, charitable Institution rent out their space to agencies for advertiseme....
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....erm Educational Institution in terms of Notification No 12/2017 dated 28.062017 defined "educational institution" in clause 2(y) means an institution providing services by way of, • pre-school education and education up to higher secondary school or equivalent; • education as a part of a curriculum for obtaining a qualification recognised by any law for the time being in force; • education as a part of an approved vocational education course; The Applicant institution since comply with the above criterion and hence it enjoys Undisputed status as "educational institution" and thus qualify for remaining out of the scope of the provisions of GST Law. 1.05. Applicant institution's factual status in the context of GST Act, judicial pronouncement, determination of disputed questions under earlier laws, Material published by the GST Council/Others and further to the matter decided in advance ruling under the present GST Law so far. The applicant institution is aware of the verdict of judicial pronouncement, determination of disputed questions under earlier laws and matter decided in advance ruling under the present GST ....
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....applicant has placed reliance on the following judicial pronouncements. II. Judicial pronouncements in support of Applicants Submission. i. Hon'ble Supreme Court in the case of Commissioner of Sales Tax Vs. Sai Publication Fund (2002) 4 SCC 7 (SC) = 2002 (3) TMI 45 - SUPREME COURT , where in the Supreme Court categorically held that where the main activity is not business, then any incidental or ancillary transaction, unless established by the revenue department to be an independent business transaction, will also be considered as charitable only & not business. The Supreme Court held that where the main & dominant activity of the assessee Society in that case was to spread message of Sai Baba, then bringing out publications & sale thereof by the assessee Society to its devotees at cost price did not amount to business. ii. Hon'ble Supreme Court in the case of CIT Vs. Gujarat Maritime Board (2007) 14 SCC 704 (SC) = 2007 (12) TMI 7 - SUPREME COURT , where in the Hon'ble Supreme Court held that if the primary or predominant object of the Society is charitable, any other object which might not be charitable but which is incidental or ancillary ....
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....ermination Order dated 2-12-1994 in the case of M/s National Safety Council: Activity of selling educational and promotional literature and materials like safety calendars, pamphlets, posters etc, is ancillary to the main objective of educational campaigns. It is held that as per Exception-Il to section 2(11) of the Bombay Sales Tax Act, 1959, he cannot be treated as a dealer, 3 NO.DDQ-11/2008/Adm-3/34/B-4 Mumbai, dt. 18.9.08 Vipassana Research Institute, Mumbai- Following Supreme Court judgement in the case of M/s Sai Publication Fund (126 STC 288) it is held that in the present case, the manufacturing, buying or selling of the books and the CDs are integrally connected with the objects of the Trust. The secondary activities were integrally connected with the objects of the Trusts. The applicant is not a dealer for the purposes of the MVAT Act 1.07. The Applicant Institution cannot be held as having carrying on any Business. From the above and having regard to the activity of Applicant Institution it would be clear that: i. The sole objective of the applicant being attending the health need of rural India through medical education and t....
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....ds ten lakh rupees. l. Applicant institution is not covered by the above provision in view of following facts. a. At the outset it is submitted that the applicant institution is not carrying on any activity in the nature of business as elaborated here-in-above and therefore there is no obligation to get registered u/s 22(1) of the CGST Act, 2017. In alternative in the event by any stretch of imagination it is treated as business and thus covered as supply then still there is an exemption in relation to services carried out by Society as "Educational Activity" where such exemption is meant for them who are in business and the law wants to exclude the given services. However, in any case, providing exemptions cannot go beyond the definition clause of 'business'. Unless the entity falls within the meaning of 'business' it cannot be subjected to tax based on any other criteria and therefore exemption would be the last resort. b. In alternative the applicant submits that, even by any stretch of imagination if it is treated that the activity of applicant institution amount to providing services falling within the scope of Supply then the receipt....
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.... a. Any person engaged exclusively in the business of supplying goods or services or both that are not liable to tax or wholly exempt from the tax under this Act or under the Integrated Goods and Services Tax Act; b. An agriculturist, to the extent of supply of produce out of cultivation of land ii. In absence of any taxable service the applicant institution is not obliged to obtain registration u/s 22. The department has already made it clear in terms of notification issued that in case there is no taxable supply event then the person is not required to obtain the registration and those who on account of migration obtained GST registration can opt for cancellation thereof. III. Compulsory registration in certain cases - Section 24 of CGST Act 2007 provides for Compulsory registration in certain cases as under Notwithstanding anything contained in sub-section (l) of section 22, the following categories of persons shall be required to be registered under this Act, i. Persons making any inter-State taxable supply; ii. Casual taxable persons making taxable supply; iii. Persons who are required to pay tax under rev....
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....g services by way of, • pre-school education and education up to higher secondary school or equivalent; • education as a part of a curriculum for obtaining a qualification recognised by any law for the time being in force; • education as a part of an approved vocational education course; Since the applicant institution comply with the conditions prescribed above and hence its activity of education falls within the scope of above exempt services and accordingly charges collected from students for imparting medical education to them would fall under this exempt category of services. • Further The said notification at item no. 74 under the Heading 9993 provided exemption to the supply of Services by way of Health Care Services by a clinical establishment, an authorised medical practitioner or para-medics; • It is provided in clause 2 definition at item no. (zg) which defines "health care services" means any service by way of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognised system of medicines in India and includes services by way of transportation of the patient....
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....care services" by hospital which covers vide range of services in respect of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognised system of medicines in India, As stated, the applicant institute collects vary nominal charges from patients diagnosed and treated through the OPD section of hospital which inter alia includes for various pathological and/or high-level investigation and also for medicines and consumables provided the in order to cure from varied illness and as such charges would fall within the exempt category "health care services." as composite supply. iii. Whether the nominal charges received from patients (who is an essential clinical materials for education laboratory) towards an "Unparallel Health Insurance Scheme" in order to retain their now at one end for the purpose of imparting medical education and in alternative provide them the benefit of affordable and concessional rates for investigations and treatment at other end would fall within the meaning of "supply" eligible for exemption under the category of "health care services." It is submitted that in order to comply with such mandatory re....
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.... 64 of the notification no. 12/2017 issued on 27.06.2017. 3. Key findings which are having bearing on deciding the questions in Issue. i. However the applicants institutions fact are completely different since its main domain is to provide medical education for implementation of the effective health delivery system to the rural masses in general and those unprivileged in particular and the activity of the institution is on account of utter failure of Government in attracting the qualified and trained Doctors for fulfilling the said promises by going and settling down in the rural area and as such cannot be tagged as business activity and thus obliging to comply with the provisions of GST Law. ii. The Applicant's submission here-in-above, contending that it is not liable to be registered under the GST Act , nowhere goes contrary to these Judgements since the Applicant Institution was specifically excluded from the Scope of Dealer in the light of Exception II to section 2(8) which inter alia excluded the "Educational institution" carrying on the activity of Buying, Selling, manufacturing in performance of its function for achieving its object and the Institut....
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....n view of provisions of Section 23 of the said act as there is no taxable liability. Comments:- Applicant is providing the services of medical education and health care services. In this regard, the relevant statutory provisions in respect of the services rendered by healthcare services/clinical establishment and services provided by an educational institution is mentioned herewith, (i) Notification No. 12/2017-Centra1 Tax (Rate) dated: 28.06.2017. Sr. No. Chapter, No. Section, Heading, Group or Service Code (Tariff) Description of Services Rate (per cent.) Condition 1 2 3 4 5 66 Heading 9992 Services provided - (a) by an educational institution to its students, faculty and staff; (b) to an educational institution, by way of,- (i) transportation of students, faculty and staff; (ii) catering, including any mid-day meals scheme sponsored by the Central Government, State Government or Union territory; (iii) security or cleaning or housekeeping services, performed in such educational Institution; (iv) services relating to admission to, or conduct of examination by, such institution; upto higher secondary: Provided that nothing. contained in ....
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....pare their own food; then no ITC will be available on inputs including capital goods and in turn if they supply food to the doctors and their staff; such supplies, even when not charged, may be subjected to GST. Health care services provided by a clinical establishment, an authorized medical practitioner or para-medics are exempt. (Sl. No. 74 of notification No. 12/2017- CT(Rate) dated 28.06.2017 as amended dated 28.06.2017 as amended senior doctors/ consultants/ technicians, fired by the hospitals, whether employees or not, are healthcare services which are exempt. (2) Healthcare services have been defined to mean any service by way of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy. In any recognised system of medicines in India [para 2(zg) of notification No. 12/2017-CT(Rate)]. Therefore, hospitals also provide healthcare services. The entire amount charged by them from the patients including the retention money and the fee/payments made to the doctors etc., is towards the healthcare services provided by the hospitals to the patients and is exempt, (3) Food supplied to the in-patients as advised by the doctor/nutritionists is a part of ....
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....amount received on account of disposal of wastes would fall within the meaning of supply. Therefore, they are required to be registered under this act. III. Whether they are liable for registration under the provisions of Section 22 of the CGST Act, 2017 or they remain outside the purview of registration in view of provisions of Section 23 of the said act as there is no taxable liability, Comments :- In this regard the provisions of Section 22 & 23 of the CGST Act, 2017 is as under. 22. Persons liable for registration (1) Every supplier shall be liable to be registered under this Act in the State or Union territory, other than special category States, from where he makes a taxable supply of goods or services or both, if his aggregate turnover in a financial year exceeds twenty lakh rupees: Provided that where such person makes taxable supplies of goods or services or both from any of the special category States, he shall be liable to be registered if his aggregate turnover in a financial year exceeds ten lakh rupees. (2) Every person who, on the day immediately preceding (he appointed day, is registered or holds a licence under an existing law; shall be liable to ....
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.... Applicant has submitted that they are an NGO registered as a Charitable Society at Sevagram, under the Registration of Societies Act, 1860 vide registration No.95/64 (Wardha) & are also registered under The Bombay Public Trust Act, 1950 vide registration No.F-87 (W), with the sole objective of attending the health needs of rural India. They are also registered under Section 12AA of the Income Tax Act, 1961 besides having recognition under The Foreign Contribution Regulation Act 1976. They have also submitted that "MAHATMA GANDHI INSTITUTE OF MEDICAL SCIENCES" (MGIMS) was established in 1969 as a JOINT PROJECT with an agreed arrangement for funding the said project by Govt. of India, Govt. of Maharashtra and Applicant Society in the ratio of 50:25:25 respectively. They have further submitted that the Governing Council of MGIMS, as per University Statute comprises of Ten Members and a Chairman out of which, five Members are nominated by Kasturba Health Society and the remaining five Members are nominated by Central and State Governments. From the above we find that the applicant and MGIMS can be considered as distinct persons since MGIMS is a joint project between the applicant ....
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..... This submissions also reveal that the management of the Hospital i.e MGIMS are different from the applicant. In view of the above observations we refer to the questions raised in the subject application which are as under:- Question No. (i) : Whether the applicant, a Charitable Society having the main object and factually engaged in imparting Medical Education, satisfying all the criteria of "Educational Institution", can be said to be engaged in the business so as to cast an obligation upon it to comply with the provisions of Central Goods and Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 in totality. In view of the submissions made by the applicant we find that it is MGIMS which appears to be engaged in imparting Medical Education and not the applicant. The applicant has entered into a joint project with the State and Central Governments to form MGIMS which has a different form from that of the applicant. Hence, the applicant cannot be said to be satisfying all the criteria of an "Educational Institution". Question No. (ii) Whether the applicant, a Charitable Society having the main object and factually engaged in imparting Medical Education,....
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..... The applicant has not given details of the business conducted by it and therefore considering the fact that it is MGIMS and not the applicant who are imparting Medical Education, the liability of the applicant to obtain registration will depend on the facts and circumstances of their business. Question No. (iii)(a) :- Whether the fees and other charges received from students and recoupment charges received from patients (who is an essential clinical material for education laboratory) would constitute as "outward supply" as defined in section 2 (83) of The Central Goods and Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 and if yes then whether it will fall in classification entry at Sr. No 66 or the portion of nominal amount received from patients (who is an essential clinical material for education at Sr. No. 74 in terms of Notification 12/2017 Central Tax - dt. 28/6/2017. From the submissions made by the applicant we find that such fees and other charges and recoupment charges appear to be collected by MGIMS/Kasturba Hospital. Since the supply in this case is not done by the applicant, as per Section 95 of the CGST Act, they cannot apply for advan....
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....ns made by the applicant we find that such amounts appear to be collected by MGIMS/Kasturba Hospital and since the supply in this case is not done by the applicant, as per Section 95 of the CGST Act, they cannot apply for advance ruling and the said matter is outside the purview of this authority. 05. In view of the extensive deliberations as held hereinabove, we pass an order as follows: ORDER (Under section 98 of the Central Goods and Services Tax Act, 2()17 and the Maharashtra Goods and Services Tax Act, 2017) No. GST-ARA-120/2018-19/B-51 Mumbai, dt. 04/05/2019 For reasons as discussed in the body of the order, the questions are answered thus - Question (i): Whether the applicant, a Charitable Society having the main object and factually engaged in imparting Medical Education, satisfying all the criteria of "Educational Institution", can be said to be engaged in the business so as to cast an obligation upon it to comply with the provisions of Central Goods and Service Tax Act, 2017 and Maharashtra Goods and Service Tax Act, 2017 in totality. Answer :- In view of the discussions made above it is MGIMS which appears to be engaged in imparting medical educat....