GOA UNIVERSITY 
vs. 
JOINT COMMISSIONER OF
CENTRAL GOODS AND SERVICE
TAX & ORS.

WRIT PETITION No. 723/2024
HIGH COURT: Bombay

DATED: 15.04.2025

Citation: 2025 Taxo.online 432

No GST on affiliation fees of educational institutions

Demand – Service tax on affiliation fees – GST on educational institutions – Petitioner submits educational activities should not be classified as commercial activities – Services by petitioner including affiliation and examination services covered under exemption notifications

Held: Writ petition allowed – High Court ruled services provided by educational institution to its students faculty and staff exempt from GST- Court agreed term education should extend beyond teaching and instruction to include curriculum design, affiliation, and degree conferment – Incomes from rent/license fee received from teachers or staff are exempt from tax as they are residential in nature and services rendered to faculty – University affiliation fees such as registration fees and convocation fees not amenable to GST as they are not consideration as contemplated in Section 7 of CGST Act – Impunged show cause notice quashed.

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