GST Exemption for NSDC Training Partner Services | AAR

Case details: Intellipaat Software Solutions (P.) Ltd., In re - [2025] 177 taxmann.com 388 (AAR - KARNATAKA)

Judiciary and Counsel Details

• • Prathap Kumar S. & Kalyanam Rajesh Rama Raoa, Member
  • Prashanth S Shivadass, Adv. for the Applicant.

Facts of the Case

The applicant is an online education company engaged in providing training in areas such as Data Science, Artificial Intelligence, Cloud Computing and other domains aimed at enhancing the skills of working professionals. The applicant agreed with the National Skill Development Corporation (NSDC) and was approved as a Training Partner for the implementation of the “Market-led Fee-Based Services Scheme”, which had been introduced and implemented by NSDC. Under this arrangement, NSDC charges a fee for conferring Training Partner status, and the applicant is obliged to deliver training programs in line with the scheme.

AAR Held

In its application before the Authority for Advance Ruling, Karnataka, the applicant sought a ruling on whether the services provided under the said scheme would attract GST and whether they would be eligible for exemption under Entry 69 of Notification No. 12/2017-Central Tax (Rate), dated 28th June 2017, as amended by Notification No. 08/2024-Central Tax (Rate), dated 8th October 2024.

The Authority examined the scope of Entry 69, which exempts from GST any service provided by an NSDC-approved training partner in relation to the National Skill Development Programme or any other scheme implemented by NSDC. It was observed that the exemption would apply only if two conditions were satisfied: first, the entity must hold approval as a training partner of NSDC, and second, the services must be rendered in connection with a scheme introduced and implemented by NSDC. On verification, the Authority found that the applicant had been duly approved as a training partner by NSDC and had entered into an agreement with NSDC for execution of the Market-led Fee Based Services Scheme, which was an NSDC-implemented scheme. Thus, both conditions under Entry 69 stood fulfilled. Accordingly, the Authority held that the services provided by the applicant under the Market-led Fee Based Services Scheme are squarely covered by the exemption available under Notification No. 12/2017, as amended. It was ruled that the applicable rate of GST on such services is Nil and that the applicant is fully eligible to claim exemption. The ruling was delivered in favour of the assessee.