AI Drafter 
TaxTMI 
TaxTMI 
2026 (5) TMI 118
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.... Standard Level of Education Age Group 5 to 8 Primary 11-14 years 9 to 10 Secondary 15-16 years 11 to 12 Higher Secondary 16-18 years 3. The question raised by the applicant is as under: "1. Whether the academic coaching services provided by Friends Classes, Surat to students of Standards 5 to 12 (GSEB/CBSE curriculum) are exempt under Entry 66 of Notification No. 12/2017-CTR as "education services" or are taxable @18% under SAC 999293 as "commercial coaching services?" 4. Personal hearing was granted on 08.04.2026 wherein Shri Bhavesh D. Saraiya, C.A., appeared on behalf of the applicant and reiterated the facts & grounds as stated in the application. The representative has also submitted additional reply on 08.04.2026 by the applicant, which, in brief is as under: (i) They have established their tuition classes i.e. "Friend Classes" on 1st July, 1984 and have been conducting classes in this institute very well for the students of Std. 5 to 12 for the last 42 years with the motive of providing best education. (ii) School teaching is necessary and compulsory. Schools teach their subjects in the best possible manner....
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....der SAC 999293 as "commercial coaching services. For the purpose, it becomes obligatory to refer to the relevant Notifications of the Good and Services Tax Act, 2017. We find that Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 contains a comprehensive list of services which are exempted from the Goods and Services Tax. Entry No.66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 (as amended) reads as under: [TO BE PUBLISHED IN THE GAZZETE OF INDIA, EXTRAORDINARY, PART II, SECTION 3, SUB-SECTION (i)] Government of India Ministry of Finance (Department of Revenue) Notification No. 12/2017-Central Tax (Rate) New Delhi, the 28th June, 2017. G.S.R ...... (E) .- In exercise of the powers conferred by sub-section (1) of section 11 of the Central Goods and Services Tax Act, 2017 (12 of 2017), the Central Government, on being satisfied that it is necessary in the public interest so to do, on the recommendations of the Council, hereby exempts the intra-State supply of services of description as specified in column (3) of the Table below from so much of the central tax leviable thereon under sub-section (1) of section 9 of the said Act, ....
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....of "Educational institution" as mentioned in the aforementioned Notification. "Educational Institution" has been defined at para-2(y) of the aforementioned notification and reads as under: (y) "educational institution" means an institution providing services by way of,- (i) pre-school education and education up to higher secondary school or equivalent; (ii) education as a part of a curriculum for obtaining a qualification recognised by any law for the time being in force; (iii) education as a part of an approved vocational education course; 8. We find that the applicant is engaged in imparting academic coaching to students enrolled in schools affiliated with recognized education boards (GSEB/CBSE) i.e. supplementary education in subjects taught in school to students studying in classes 5 to 12 (falling in the age group 11-18 years) in order to help them improve their academic performance. As per Oxford Learner's Dictionaries, "supplementary" means provided in addition to something else-often to improve, complete, or support it. Therefore, supplementary education refers to additional training, courses, or learning materials that complement m....
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....ive list of services which are taxable under the GST regime. We also find that all the services are covered/classified under Chapter 99 in the GST regime. On going through the said list, we find that the services provided by the applicant would be aptly covered under the head 'Education Services' falling under Entry No.30 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017. Entry No. 30 to Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017 reads as under: [TO BE PUBLISHED IN THE GAZZETE OF INDIA, EXTRAORDINARY, PART II, SECTION 3, SUB-SECTION (i)| Government of India Ministry of Finance (Department of Revenue) Notification No. 11/2017-Central Tax (Rate) New Delhi, the 28th June, 2017. G.S.R ...... (E).- In exercise of the powers conferred by sub-section (1) of section 9, sub-section (1) of section 11, sub-section (5) of section 15 and sub-section (1) of section 16 of the Central Goods and Services Tax Act, 2017 (12 of 2017), the Central Government, on the recommendations of the Council, and on being satisfied that it is necessary in the public interest so to do, hereby notifies that the central tax, on the intra-State supply of services of....