Educational expenses- Contradictory Advance Rulings of AAR Rajasthan

In Symmetric Infrastructure Pvt. Ltd., Kota, (Raj) (2021) 36 J.K.Jain’s GST & VR 226, Ruling dated 2.9.2021, the Coaching services to students, along with supply of goods/printed material/test papers, uniform, bags and other goods, which are not charged separately but a consolidated amount is charged, have been treated as a ‘Composite Supply’, by the AAR of Rajasthan State.

Whereas, now, on 28.12.2021, in Resonance Eduventures Limit, Kota (Raj) (2022) 37 J.K.Jain’s GST & VR 19, it has been held that Coaching Services to students including supply of goods/printed material/test papers, uniform, bags and other goods to students, which are not charged separately but a consolidated amount is charged, the major component of which is imparting of coaching will be treated as “Mixed Supply” of goods & services liable to highest rate of tax.

It is really surprising that both the educational Institutions are from Kota and the matter for Advance Ruling was also the same. However, the AAR, Rajasthan has give contradictory Advance Rulings in both the above cases.

In such a situation how a taxable person will manage their affair? No any clarification has been issued by the Commissioner of the State. Matter requires urgent attention of the State.