AAR Rules Student Services Charged Directly Not Exempt from GST

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  • Last Updated on 22 September, 2025

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AAR ruling student services GST exemption

Case Details: Protego Services LLP, In re - [2025] 176 taxmann.com 147 (AAR - GUJARAT)

Judiciary and Counsel Details

  • Kamal Shukla & Vishal Malani, Member
  • Ms. Raveena Narang, CA & Ms. Arptia Modi, Adv. for the Applicant

Facts of the Case

The applicant, engaged in the business of providing transportation and catering services to students of a school, collected fees directly from the students for such services. No consideration for these services was received by the school administration. The applicant sought a ruling on whether these services would be eligible for exemption under serial no. 66(b)(i) & (ii) of Notification No. 12/2017-Central Tax (Rate), dated 28-06-2017, as services provided to an educational institution. It was contended that since the services related to students and staff members of the school, exemption might be applicable. The matter was accordingly placed before the Authority for Advance Ruling (AAR), Gujarat.

AAR Held

The AAR held that the applicant is collecting charges for transportation and catering directly from the students, and no payment is received from the school administration. Consequently, no services are rendered to the school by the applicant, and the school has no role in the transaction. The AAR observed that services provided by the applicant to the students cannot be considered as services provided to the school. Accordingly, the applicant is not eligible for exemption under serial no. 66(b)(i) & (ii) of Notification No. 12/2017-Central Tax (Rate), dated 28-06-2017 in respect of transportation and catering services provided to students.

List Of Cases Reviewed

  • Muniyasamy Abinaya, In re [2023] 154 taxmann.com 383/100 GST 383/78 GSTL 93 (AAR – T.N.)
  • Akshar Travels v. C.C.E. & S.T. [ST Appeal No. 263 of 2012-DB, dated 17-8-2023]
  • Sangam Travels v. CCE & ST [FINAL ORDER No. 70074 of 2017, dated 10-1-201 [Para 17] – distinguished

List of Cases Referred To

  • Muniyasamy Abinaya, In re [2023] 154 taxmann.com 383/100 GST 383/78 GSTL 93 (AAR – T.N.) (para 5)
  • Akshar Travels v. C.C.E. & S.T. [ST Appeal No. 263 of 2012-DB, dated 17-8-2023] (para 5)
  • Sangam Travels v. CCE & ST [FINAL ORDER No. 70074 of 2017, dated 10-1-2017] (para 5)

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied