In re Allen Career Institute Private Limited (GST AAR Rajasthan)
Summary: The Rajasthan Authority for Advance Ruling (Goods and Services Tax), in Advance Ruling No. RAJ/AAR/2026-27/11 dated 30 July 2026, considered an application by M/s ALLEN CAREER INSTITUTE PRIVATE LIMITED concerning the applicability of Notification No. 13/2020-Central Tax dated 21 March 2020, as amended, and the requirement to issue e-invoices for coaching services where parents, guardians or sponsoring business enterprises pay the consideration and may furnish a GSTIN. The applicant provides commercial coaching services for competitive examinations including IIT-JEE and NEET through physical centres and digital/online modes and proposed additional batches of courses. The applicant contended that under Section 2(93)(a) of the CGST Act, the person liable to pay consideration is the recipient and that, where a parent, guardian or business enterprise furnishes a valid GSTIN, e-invoicing under Rule 48(4) of the CGST Rules read with Notification No. 13/2020-Central Tax is mandatory. It also submitted that the supplier was not required to investigate the recipient’s business purpose or eligibility for input tax credit (ITC). The jurisdictional officer disputed the premise that the fee-paying person is necessarily the recipient, contending that the coaching service is rendered to and consumed by the student, and also raised maintainability objections under Sections 95(a), 97(2) and 98(2).
