Education Consultancy Classed as Intermediary Due to Commission-Linked Enrolments | AAR

  • Blog|News|GST & Customs|
  • 2 Min Read
  • By Taxmann
  • |
  • Last Updated on 10 November, 2025

Latest from Taxmann

education consultancy

Case Details: Maryland Study Abroad (P.) Ltd., In re - [2025] 179 taxmann.com 541 (AAR-KERALA)

Judiciary and Counsel Details

  • Jomy Jacob & Mansur M.I., Member
  • Subin Babu, CA for the Applicant.

Facts of the Case

The applicant, an education consultancy service provider, submitted that it facilitated admissions to foreign universities by identifying, guiding, and referring prospective students under a Recruiting Service Agreement. Under the agreement, students paid tuition directly to the universities, and the applicant earned commission contingent on actual enrollments. It was contended that it acted on a principal-to-principal basis and did not supply education on its own account, seeking a determination on whether its services qualified as intermediary services. The matter was accordingly placed before the Authority for Advance Ruling (AAR).

AAR Held

The AAR held that the education consultancy services constituted intermediary services under Section 2(13) of the IGST Act. It was observed that the commission-linked arrangement, the absence of a fixed retainer, and the applicant’s role in identifying, guiding, and channelling students demonstrated that it merely facilitated the supply of education between the universities and the students. It was further noted that the applicant did not supply educational services on its own account, and the facilitation was contingent entirely on successful student enrollments. Accordingly, the services were classified as intermediary services.

List of Cases Referred to

  • Center for International Admission and Visas (CIAV), In re [TSAAR Order No. 09 of 2024, dated 1-2-2024] (para 4.10)
  • Global Reach Education Services (P) Ltd, In re [Advance Ruling No. 15/WBAAR/2018-19, dated 8-5-2018] (para 7.9.1)
  • DKV Enterprises (P). Ltd, In re [Advance Ruling No. AAR/AP/02(GST)/2020, dated 27-2-2020] (para 7.9.1)
  • Vishakhar Prasad Bhave, In re [Advance Ruling No. GST-ARA-03/2017-18/B-07, dated 22-1-2018] (para 7.9.1)
  • Sabre Travel Network India (P). Ltd, In re [Advance Ruling No. GST-ARA-01/2017-18/B-01, dated 9-1-2018] (para 7.9.1)
  • Global Reach Education Services (P). Ltd., In re [Order No. 06/WBAAAR/Appeal/2019, dated 20-3-2019] (para 7.9.1)
  • Ushabala Chits (P) Ltd, In re [Order-in-Appeal No. AAAR/AP/03(GST)/2020, dated 22-6-2020] (para 7.9.1)
  • Dharmendra M. Jani v. Union of India [2023] 76 GSTL 297 (Bom.) (para 7.9.1)
  • Sunrise Immigration Consultants Put. Ltd. v. CCE [Final Order No. 62104 of 2018, dated 3-8-2018] (para 7.9.4).

Disclaimer: The content/information published on the website is only for general information of the user and shall not be construed as legal advice. While the Taxmann has exercised reasonable efforts to ensure the veracity of information/content published, Taxmann shall be under no liability in any manner whatsoever for incorrect information, if any.

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

Leave a Reply

Your email address will not be published. Required fields are marked *

«
»

Everything on Tax and Corporate Laws of India

To subscribe to our weekly newsletter please log in/register on Taxmann.com

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