Professional Coaching for ACCA, CMA and CPA Not GST Exempt: Kerala AAR

In re Learnfluence Education Private Limited (GST AAR Kerala)

Summary: Kerala Authority for Advance Ruling considered five GST issues raised by Learnfluence Education Private Limited, a private coaching institution providing commerce-focused professional courses including Chartered Accountancy (CA), Association of Chartered Certified Accountants (ACCA), Certified Management Accountant (CMA India and CMA USA), Company Secretary (CS), Certified Public Accountant (CPA USA), Diploma in International Financial Reporting Standards (DipIFRS–ACCA), and integrated undergraduate and post-graduate programmes in collaboration with Jain University.

On the principal issue, the Authority examined whether coaching and training for qualifications administered by professional bodies such as ACCA and IMA USA qualified for exemption under Serial No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017. It held that the applicant was neither providing pre-school or higher-secondary education nor an approved vocational education course. Although the professional qualifications may be recognised and the courses follow prescribed curricula, the applicant itself did not conduct the examinations or award the qualifications.

The professional bodies or collaborating universities performed those functions. The applicant was therefore not an “educational institution” within paragraph 2(y) of the notification and its coaching/training services were not exempt. The Authority relied on the Kerala Appellate Authority’s decision in Logic Management Training Institutes Pvt. Ltd., which held that private coaching institutions preparing students for examinations conducted by other bodies do not become educational institutions on that account.