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TMI Blog2019 (10) TMI 757X X X X Extracts X X X X X X X X Extracts X X X X ..... e the applicant does not qualify as educational Institution. The applicant is collecting the exact amount payable to institute or college or universities as exam fee from the students (service recipient) and remits the Same amount to the respective institute or college or universities (third party) without any profit element or additions, on the authorization of the student. This payment is Separately indicated in the invoice issued to the respective students. The applicant providing this kind of services to the student in addition to the services as training and coaching institute - Hence the applicant satisfies all the conditions of the pure agent as narrated in the Rule 33 of the CGST Rules, 2017. Therefore amount of fee collected by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f education and set up of coaching and training classes/ Centres in relation to the same. 3. In this process the applicant collects certain amount as exam fee from the students and remits the same to the respective institute or college or universities without any profit element. In One such transaction the applicant collects CIMA (Chartered Institute of Management Accountants) exam fee from the Students registered with applicant for coaching and remits the exact amount collected to CIMA on behalf of the students. 4. The Applicant had sought advance ruling on the question: Does the activity of collecting/ exam fee (charged by any university or institution) from the students and remitting to that particular univer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acy, mining, military, dance, acting, sports, journalism and other field of education and set up of coaching and training classes/ centers in relation to the same. 6.2 In this process, the applicant collects certain amount as exam fee from the students and remits the same in bulk to the respective institute or college or universities without any additional charges or profit element. When they collect fee and make the payment on authorization of the student in such cases, the applicant States that he acts as pure agent and this payment is separately indicated in the invoice issued to the respective students. FINDINGS AND DISCUSSION 7. We have considered the submissions made by the applicant in their application ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is not a subject matter of this advance ruling 7.2 In this process applicant also Collects certain amount as exam fee from the students and remits the same to the respective institute or College or universities without any additional charges or profit element. The applicant makes the payment in bulk on behalf of all students, after Collecting the same and then issues invoice to the student for the reimbursement of the payment made on behalf of him. This payment is separately indicated in the invoice issued (to the respective students, 7.3 Educational institution is defined in Para 2 (y) of the Notification No. 12/2017-Central Tax (Rate), the 28 th June, 2017 as an institution providing services by way of: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... udents mentioning separately the fee collected for the coaching or training classes and fee collected as examination fee. 7.5 The applicant Contends that when they collect fee and make the payment to CIMA on authorization from the student the in such cases the applicant acts as pure agent and applicant collects the exact amount from the student and remit the same to the CIMA without any addition, This payment is separately indicated in the invoice issued to the respective Students. The applicant is providing this kind of facility to the Student in addition to the services as training and coaching institute. 8. Rule 33 of the CGST Rules 2017 reads as under. Value of supply of Services in case of pure agent: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... own account. 8.1 The applicant is collecting the exact amount payable to institute or college or universities as exam fee from the students (service recipient) and remits the Same amount to the respective institute or college or universities (third party) without any profit element or additions, on the authorization of the student. This payment is Separately indicated in the invoice issued to the respective students. The applicant providing this kind of services to the student in addition to the services as training and coaching institute. Hence the applicant satisfies all the conditions of the pure agent as narrated in the Rule 33 of the CGST Rules, 2017. Therefore amount of fee collected by the applicant from the student as exam ..... X X X X Extracts X X X X X X X X Extracts X X X X
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