In re Sanjaykumar Ishwerlal Sadadiwala (GST AAR Gujarat)
Summary : The applicant, a proprietor of a coaching institute, is engaged in providing academic coaching to students from Standards 5 to 12 enrolled in schools affiliated with recognized boards such as GSEB and CBSE. The services offered include supplementary education in school subjects aimed at improving academic performance through additional practice, conceptual clarity, and exam preparation. The applicant sought an advance ruling on whether such coaching services qualify as exempt “education services” under Entry 66 of Notification No. 12/2017-Central Tax (Rate) or are taxable as “commercial coaching services” under SAC 999293 at 18%.
The applicant argued that their services contribute to education, which is a fundamental right, and emphasized the social importance of making education accessible. They contended that supplementary coaching supports students in achieving better results and should not be taxed, especially for students up to the higher secondary level.
The Authority for Advance Ruling examined the relevant provisions of the GST law, including Notification No. 12/2017-Central Tax (Rate) , which grants exemption to services provided by an “educational institution.” The definition of “educational institution” includes entities providing pre-school education, education up to higher secondary level, education as part of a recognized curriculum, or approved vocational education courses.
