GST Exemption Not Available on University Affiliation Fees | HC

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GST on university affiliation fees

Case Details: Bharathidasan University vs. Joint Commissioner of GST (ST-Intelligence) [2026] 183 taxmann.com 565 (Madras)

Judiciary and Counsel Details

  • Dr. G. Jayachandran & K.K. Ramakrishnan, JJ.
  • V.R. Shanmuganathan for the Petitioner.
  • R.Sureshkumar, Additional Government Pleader for the Respondent.

Facts of the Case

The petitioner filed a writ petition challenging the applicability of GST on affiliation fees received from affiliated colleges. It was submitted that the fees were exempt under Notification No. 12/2017, as services relating to student admission or conduct of examinations. The respondents, including the Joint Commissioner of GST contended that affiliation fees were not services provided to students for admission or for conducting examinations, and accordingly issued intimations of liability with interest and penalty. The petitioner relied on its claim that affiliation was essential for colleges to admit students. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the affiliation fees collected by the university did not constitute services relating to the admission of students or the conduct of examinations, and were therefore not eligible for exemption under Notification No. 12/2017, dated 28-6-2017. The Court observed that while affiliation was a prerequisite for colleges to admit students, it fell outside the definition of services directly relating to admission or examination conduct, which formed the limited scope of the exemption. Relying on Section 11, read with Section 9, of the CGST Act and Tamil Nadu GST Act. The Court dismissed the petition, and upheld the university’s liability to pay GST on affiliation fees.

List of Cases Reviewed

List of Cases Referred to

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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