TaxTMI 
TaxTMI 
2025 (8) TMI 477
X X X X Extracts X X X X
X X X X Extracts X X X X
....an application for Advance Ruling under Section 97 of CGST Act, 2017, read with Rule 104 of the CGST Rules 2017 and Section 97 of KGST Act, 2017 read with Rule 104 of KGST Rules 2017, in form GST ARA-01 discharging the fee of Rs. 5,000/- each under the CGST Act KGST Act. 2. The Applicant is a Private Limited Company engaged in online education offering training in various domains such as Big Data, Data Science, Artificial Intelligence, Business Intelligence, Cloud Computing etc., to enhance the skills of the working professionals. The applicant entered into an agreement dated 12-06-2024 with NSDC, for implementation of "Market-led Fee Based Services", notified by NSDC, as a Training Partner. 3. In view of the above, the applicant has ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....in participation with National Skill Development Corporation; that NSDC approves various entities to carry out the national skill development programs and such approved entities are given the status of 'Approved Training Partner', that the training program shall be subject to the terms and conditions provided by NSDC. 5.3 The Applicant stated that one of the schemes introduced and implemented by NSDC is the 'market led Fee-based Services' (hereinafter referred to as 'scheme') which aims to establish a framework for aggregate and standardized training in high growth sectors. For implementing these trainings, NSDC has engaged various third parties as its training partners on a service-to-service basis and intends to provide joint certifica....
X X X X Extracts X X X X
X X X X Extracts X X X X
....eading Description of Service CGST Rate (%) SGST Rate (%) IGST Rate (%) 9992 Education Services 9 9 18 6.2 The Applicant submitted that the Central Government has issued another Exemption Notification bearing Notification No. 12/2017-Central Tax (Rate), dated 28.06.2017 (hereinafter referred to as 'Exemption Notification') declaring various services as exempted services thereby exempting the GST payable on those services. The relevant entry is provided below: SL.No. Chapter, section or Heading, Group or Service Code (Tariff) Description of Service Rate (per cent) Condition 69 Heading 9992 or Heading 9983 or Heading 9991 Any service provided by, (a) The National Development Corpo....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ces" scheme. 6.5 The Applicant intends to rely upon the ruling of the Authority for Advance Ruling, Karnataka in the case of M/s Interviewbit Software Services Private Limited and the ruling of the Authority for Advance Ruling, Telangana in case of M/s Nxtwave Disruptive Technologies Private Limited. 6.6 The Applicant, in view of the above contends that the service being provided by them is an 'exempted service' in accordance with entry no. 69 of the exemption notification from the date of its agreement with NSDC and hence, the applicable rate of GST on the same would be NIL. PERSONAL HEARING/PROCEEDINGS HELD ON 16.06.2025 7. Sri Prashanth S Shivadass, Advocate & duly authorized representatives of the applicant appeared for pers....
X X X X Extracts X X X X
X X X X Extracts X X X X
....h June 2017, since they are providing training as a training partner approved by the National Skill Development Corporation in relation to 'Market led Fee-based Services Scheme, implemented by NSDC. 12. In this regard, we invite reference to the entry No. 69 Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 as amended vide Notification No. 08/2024-Central Tax (Rate) dated 08.10.2024, which is as under: SI.No Chapter, Section, Heading, Group or Service Code (Tariff) Description of Services Rate (per cent.) Condition 69 Heading 9983 or Heading 9991 or Heading 9992 Any services provided by - (a) the National Skill Development Corporation set up by the Government of India; (b) the National....