In re Unitech Engineers (Prop. Naresh Arya) (GST AAR Odisha)
The Odisha Authority for Advance Ruling (AAR) considered an application filed by M/s Unitech Engineer regarding the GST classification and exemption applicability for supply of Coursera User Licenses to the Odisha Skill Development Authority (OSDA). The Applicant, acting as a distributor and subcontractor of Coursera Inc., USA, supplied user licenses enabling technical students in Odisha to access online courses and digital skill programs hosted on Coursera’s proprietary digital platform.
The Applicant sought rulings on whether the supply was classifiable as “Education Services” under Heading 9992, whether exemption under Serial No. 72 of Notification No. 12/2017-CT (Rate) was available, whether the supply was classifiable under Heading 9973 relating to leasing or licensing services, or alternatively under Heading 9984 relating to online content services.
The factual background showed that OSDA and Coursera Inc., USA entered into a Memorandum of Understanding (MOU) dated 24.12.2023 under which Coursera agreed to provide a minimum of 5,000 user licenses for one year. These licenses enabled students to access courses in emerging technologies such as Artificial Intelligence, Robotics, Cyber Security, Data Analytics, Cloud Development, and related fields. The Applicant was appointed as distributor and subcontractor for implementation and invoicing purposes.
