GST – Goa University – Educational activities – Affiliation Services to constituent colleges

 Entry No.66 of the Notification No.12/2017-CT ® dated 28.6.2017, exempts services in relation to education as reproduced in para 44 of the judgment.

 The service provided by an educational institution to its students, faculty and staff are exempted.   The University which grants affiliation is also an educational institution.

 However, the show cause notice relied on the Circulars dated 17.6.2021 and 11.10.2024 that affiliation services of the Universities to their constituent colleges are not covered within the ambit of exemptions provided to the educational institutions.

 These clarifications are contrary to the statutory provisions of Sections 7 and 9 of the GST since the Circular assumes that the said activity of affiliation service provided by the University to their constituent colleges would qualify as supply.

 HELD that the activities of the petitioner University not being commercial in nature, are not amenable to GST. 

 Judgment dated 15.4.2025 of the High Court of Bombay at Goa in Writ Petition No.723 of 2024 of Goa University   Vs.   Joint Commissioner of Central Goods and Service Tax and others