Since 'affiliation services' provided by applicant-assessee does not relate to conduct of examination and admission of students, they do not fall within purview of exempted services under S. No 66 of Notification No.12/2017-CT(Rate) dated 28-6-2017, and 'affiliation' fees charged by applicant-assessee is not liable for exemption.
AUTHORITY FOR ADVANCE RULINGS, RAJASTHAN in the application filed by IN RE: M/S. UNIVERSITY OF KOTA - 2022 (12) TMI 1100 - AUTHORITY FOR ADVANCE RULING, RAJASTHAN held:
Facts:
- Applicant-assessee is a University set up by Government for sole purpose of providing education to students in State and it provides affiliation services to colleges on payment of affiliation fees which is paid out of fees collected from students.
- Applicant-assessee seeks advance ruling on whether services provided by applicant-assessee relating to affiliation granted to colleges for imparting education falls within purview of exempted supply and whether amount collected by way of affiliation fee, is exempted vide S. No. 66 of Notification No.12/2017-CT(Rate) dated 28-6-2017.
Held That:
- As per aforesaid notification, in order to fall within purview of 'exempted services' it is necessary that such services relates to admission of students and conduct of examination
- Since, applicant-assessee provides 'affiliation services’ which do not relate to admission of students to such course/programme in said institutions or conduct of examination for admission in institution, affiliation services provided by applicant-assessee to its constituent colleges for imparting education is a supply and does not fall within purview of 'exempted services’
- Further, exempted services on conduct of examination is related to admission to such institution and not related to examination based on which degree/title is conferred to student as is being claimed by applicant-assessee
- Therefore, 'affiliation fees' so collected by applicant-assessee is not exempted under entry SI.No.66 of Notification No. 12/2017- C.T.(Rate) dated 28.06.2017
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