In re Раскаpeer Academy Pvt Ltd (GST AAR Kerala)
Summary: Kerala Authority for Advance Ruling held that services provided by Packapeer Academy Pvt Ltd in respect of its “Junior Software Developer” vocational training course qualify for GST exemption under Entry No. 69(e)(iii) of Notification No. 12/2017-Central Tax (Rate), as amended, with effect from 10.10.2024. The Authority further ruled that the exemption extends to the entire course fee collected from students towards the NSQF-aligned Junior Software Developer training programme.
Packapeer Academy operates offline and online programmes under the brand name “Brototype” and provides various software development and IT-related training programmes. On 22.05.2025, it entered into a Memorandum of Understanding with IT-ITeS Sector Skills Council (SSC NASSCOM), which functions as an integral part of the National Association of Software and Service Companies (NASSCOM), thereby becoming its training partner. IT-ITeS SSC NASSCOM is an Awarding Body recognised by the National Council for Vocational Education and Training (NCVET).
The applicant submitted that it enrols candidates, conducts training and facilitates assessment in accordance with NASSCOM guidelines. Its Junior Software Developer course, Qualification Pack Code SSC/Q0508, corresponds to NSQF Level 4 and is supported by an NCVET-approved Qualification Pack. The Authority examined Entry No. 69 of Notification No. 12/2017-Central Tax (Rate). The original entry covered specified skill-development services provided by the National Skill Development Corporation, approved Sector Skill Councils, assessment agencies and approved training partners. The scope was subsequently revised through Notification No. 08/2024-Central Tax (Rate), effective from 10.10.2024. Amended Entry No. 69(e) separately covers a training body accredited with an Awarding Body recognised by NCVET in relation, inter alia, to any National Skill Qualification Framework-aligned qualification or skill for which NCVET has approved a qualification package.
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