Facts of the Case:

In this case, the applicant is engaged in providing academic coaching to students studying in Standards 5 to 12 under the GSEB and CBSE curriculam. The Applicant offers supplementary education aimed at improving students’ academic performance through conceptual clarity, additional practice, and exam-oriented preparation. The applicant contended that such coaching services form an integral part of the broader educational ecosystem, especially considering that school education often requires reinforcement through additional academic support.

The applicant approached the Authority for Advance Ruling seeking clarity on whether such services would qualify as exempt “education services” under Entry 66 of Notification No. 12/2017-Central Tax (Rate), or whether they would be liable to GST as “commercial coaching services.” It was argued that education up to higher secondary level is fundamental and that taxing such services would adversely affect accessibility and affordability, particularly for middle- and lower-income groups. The applicant emphasized that the services provided are closely aligned with school curricula and are essential for academic development, thereby meriting exemption.

Issue:

Whether the academic coaching services provided by the applicant to students of Standards 5 to 12 could be classified as “education services” provided by an “educational institution” and thereby qualify for exemption under Entry 66 of Notification No. 12/2017-CTR, or whether such services would fall within the ambit of taxable services under the category of “commercial training and coaching services” classifiable under SAC 999293 and liable to GST at the applicable rate.

Held That:

The AAR observed that the exemption is specifically available only to services provided by an “educational institution” as defined in the notification, which includes institutions providing pre-school education, education up to higher secondary level as part of a recognized curriculum, or education as part of an approved vocational course. The applicant, being a private coaching institute, does not provide education as part of a recognized statutory curriculum nor does it grant any qualification recognized by law.

The Authority further noted that the services rendered by the applicant are in the nature of supplementary or parallel coaching, intended to support and enhance the learning imparted by formal schools. Such services, though educational in nature, do not fall within the statutory definition of “educational institution” and hence cannot avail the exemption.

Consequently, the services were classified under Heading 9992 as “education services,” specifically under SAC 999293 pertaining to “commercial training and coaching services,” in terms of Notification No. 11/2017-Central Tax (Rate), and held liable to GST at the rate of 18% (9% CGST and 9% SGST). The Authority for Advance Ruling held that the services provided by the applicant do not qualify for exemption under Entry 66 of Notification No. 12/2017-CTR.

Case Name: In Re: M/s. Sanjaykumar Ishwerlal Sadadiwala. dated 28.04.2026