Nexus to coaching service excludes separately supplied study material, hostel, mess and unrelated ancillary collections from taxable value.

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....Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.....