RAJASTHAN TECHNICAL UNIVERSITY vs UNION OF INDIA

[2026:RJ-JD:9475-DB]
HIGH COURT OF JUDICATURE FOR RAJASTHAN AT
JODHPUR
D.B. Civil Writ Petition No. 9556/2024
Rajasthan Technical University, Kota, Rawat Bhata Rod,
Akhelgarh, Kota, 324009 Through Its Assistant Registrar (F And
A), Shri Manoj Kumar Jangid, S/o Shri Ratan Lal Jangid, Aged
About 45 Years, R/o A-608, Shubh Atlantis Apartment, Opposite
Kota University, Vivekanand Nagar, Kota - 324005
----Petitioner
Versus
1. Union Of India, Through The Revenue Secretary, Ministry
Of Finance, North Block, New Delhi - 110001
2. Commissioner, Office Of The Commissioner, Central
Excise And Central Goods And Services Tax
Commissionerate , 142-B, Sector 11, Hiran Magri,
Udaipur, Rajasthan.
3. Deputy Commissioner, Office Of The Commissioner,
Central Excise And Central Goods And Services Tax
Commissionerate (Anti - Evasion Branch), 142-B, Sector
11, Hiran Magri, Udaipur, Rajasthan.
4. Superintendent, Central Excise And Central Goods And
Services Tax Commissionerate (Anti - Evasion Branch),
142-B, Sector 11, Hiran Magri, Udaipur, Rajasthan.
5. Assistant Commissioner, Office Of The Assistant
Commissioner, Central Excise And Central Goods And
Services Tax, (Anti - Evasion Branch, Kota), Central
Rajasva Bhawan, Near C.a.d. Circle, Kota (Rajasthan)
324009.
6. State Of Rajasthan, Through The Finance Secretary
(Revenue), Finance Department, Government Of
Rajasthan, 1St Floor, Main Building, Government
Secretariat, Janpath, Jaipur, Rajasthan - 302005.
7. The Commissioner, Rajasthan Goods And Services Tax,
Ward-Ac/cto, Circle-B, Zone-Iii, Room No. 421, Zonal Kar
Bhawan, Jhalana, Jaipur, Rajasthan - 302004
----Respondents
Connected with bunch of petitions as per Appendix “A”
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For Petitioner(s) : Mr. Sharad Kothari
Mr. Kalpit Shishodia
Mr. Dinesh Kumar Bishnoi
Mr. Chirag Soni
Mr. Abhimanyu Yadhuvanshi
Mr. Bhuwaneshwar Singh Sisodia
Mr. C.S. Kotwani with
Mr. Avdesh Parashar
Mr. Ankur Mathur
Mr. Divik Mathur
Mr. Rahul Lakhwani
Ms. Adwaita Sharma
Mr. Chayan Bothra
Mr. Vinay Kothari with
Mr. Bhavyadeep Singh
For Respondent(s) : Mr. Mahaveer Bishnoi, AAG with
Mr. Harshwardhan Singh
Mr. Mrigraj Singh Rathore
Mr. Rajvendra Saraswat with
Mr. Jitesh Kumar Suthar
Mr. Rajeev Purohit
Ms. Akshiti Singhvi
HON'BLE MR. JUSTICE ARUN MONGA
HON'BLE MR. JUSTICE YOGENDRA KUMAR PUROHIT
Order
Reportable
Judgment Reserved on :- 15/01/2026
Pronounced on :- 23/02/2026
By the Court (Per, Arun Monga, J):-
1. Rajasthan Technical University , a State university set up by
Government of Rajasthan, is before this court, aggrieved against
the impugned Show Cause Notice dated 26.12.2023 and;
consequential proceedings vide which the act of affiliation granted
by it to the affiliate colleges has been included in the statutory
term “service” and; thus tax has been imposed on the University
under the provisions of CGST, 2017 and directed to pay service
tax with interest and penalty.
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2. Case of the Petitioner University is that the impugned Show
Cause Notice has been issued in contravention of the provisions of
the Central Goods and Services Tax, 2017 (CGST Act). and Rules
framed there under. It is also arbitrary and violative of Articles 14,
19(1)(g), 265 and 300A of the Constitution of India. More of it
later.
2.1. The controversy that warrants adjudication by court is
whether or not the affiliation fee charged by a University, for grant
of affiliation to its constituent college, is subject to levy of service
Tax under CGST Act.
2.2 Bunch of petitions have been filed as per Appendix ‘A’
wherein similar controversy is involved and vide this common
order and judgment all of those are being decided together.
FACTS (For convenience and brevity facts are taken from
D.B. Civil Writ Petition No.9556/2024).
3. The Petitioner University has been set up by way of State
legislative enactment i.e. the Rajasthan Technical University Act,
2006 (RTU Act). Under Section 5(xix) of the RTU Act and the
Affiliation Regulations, 2016, it is empowered to fix and recover
affiliation and related fees.
3.1. It is an affiliating university offering undergraduate (B.Tech.,
B.Arch., BHMCT) and postgraduate (M.Tech., MBA, MCA)
educational programs being imparted in its more than 140
colleges and catering to more than 40,000 students. University is
statutorily mandated to perform academic and regulatory
functions qua its affiliated colleges which include curriculum
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design, inspections, maintenance of academic standards, degree
conferment, scholarship facilitation, and grievance redressal.
3.2. Under the erstwhile Chapter V of the Finance Act, 1994 ("FA
1994"), service tax was levied by the Central Government on
various services provided within the territory of India. That
Section 66B of the FA 1994 (i.e., the charging section) provided
that the services enumerated in the negative list under Section
66D were not chargeable to service tax. Further, Clause (1) of
Section 66D of the FA 1994 provided that services by way of "pre-
school education and education up to higher secondary school or
equivalenť"; "education as a part of a curriculum for obtaining a
qualification recognized by any law for the time being in force";
"education as a part of an approved vocational education course"
were not chargeable to service tax.
3.3. Further, Central Government also issued Notification No.
25/2012-Service Tax dated 20.06.2012 whereby several services
were made exempt from payment of service tax. Serial no. 9 of
the said notification pertained to educational services wherein also
services provided by educational institutions were made exempt
from payment of service tax.
3.4. However, there was a regime change of in direct taxation on
the enactment of CGST Act, 2017.
3.5 The Central Government vide Notification No. 02/2018- CT
(Rate) dated 25.01.2018 amended serial no. 66 of the Notification
dated 28.06.2017. Vide the amended entry it was made clear that
Services provided by an educational institution to its students,
faculty and staff and by an educational institution by way of
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conduct of entrance examination against consideration in the form
of entrance fee are exempted from levy of tax.
3.6 Therefore, even in the current service tax regime, the
petitioner-University was/is of the understanding that since their
services were related to education, therefore the same were
exempt from payment of service tax. In fact, none of the other
universities charged any service tax on the affiliation fees amount.
Accordingly, the Petitioner also did not collect any service tax on
the affiliation fees and even the service tax department never
raised any demand.
3.7. Until year 2022 and even prior thereto, there was no
demand ever raised on the petitioner University for payment of
service tax. The Petitioner, therefore, did not collect the GST
amount on the affiliation fees deposited by the affiliated colleges
for the academic sessions 2017-18 to 2022-23 during the FY
2016-17 to 2021-22.
3.8. In January–March 2022, GST authorities sought extensive
details regarding affiliation and related fees collected from AY
2017–18 onwards. The Petitioner furnished the information and,
upon summons, appeared before the authorities. The Petitioner
consistently maintained that affiliation services were exempt
under Entry 66 of Notification No. 12/2017-CT (Rate) dated
28.06.2017, and that it bona fide believed GST was not applicable,
similar to the erstwhile Service Tax regime.
3.9. Despite representations and correspondence with State
authorities, the Governor’s Office, and GST officials seeking
exemption or clarification, the Department relied upon an Advance
Ruling dated 19.11.2020 in the case of Bharatyar University, Tamil
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Nadu, holding affiliation services taxable @18%, and demanded
GST with interest and penalty for AY 2017–18 to 2022–23.
3.10. Without admitting liability, the Petitioner deposited
₹4,25,86,142/- towards GST (31.01.2023) and subsequently
₹3,02,68,940/- towards interest (03.06.2023), prior to issuance of
any show cause notice.
3.11. Vide letters dated 24.11.2020, 12.11.2021 and 26.11.2022
(Annexure-4) sent by the Petitioner to the affiliated colleges for
deposit of affiliation fees for the academic years 2021-22 to 2023-
24 (FYs 2020-21 to 2022-23), the /affiliated colleges were duly
informed by the Petitioner University that GST @ 18% shall be
applicable on affiliation fee/variation fee/inspection fee/NOC fee
and other fee as and when demanded by the Government.
3.12. The relevant portions of the letters dated 24.11.2020,
12.11.2021 and 26.11.2022 are reproduced below for ease of
reference-
Letter dated 26.11.2022.
“ 5. 18% G.S.T. shall be applicable on affiliation fee/variation
fee/inspection fee/NOC fee and other fee to be deposited alongwith
regular fee. "
Letter dated 12.11.2021
“
12. GST shall be charged, on the direction of the government, if
applicable. "
Letter dated 24.11.2020.
“ 12. GST shall be charged, on the direction of the government, if
applicable. "
3.13. Meanwhile, petitioner instead received a letter dated
27.06.2023 issued by Respondent No. 3, whereby a demand was
raised with respect to the payment of penalty under section 74(5)
of the CGST/RGST Act, even after petitioner having duly paid the
GST amount along with the applicable interest rate.
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3.14. In response to the letter dated 27.06.2023, the Petitioner
University, vide its letter dated 20.09.2023, submitted that the
Petitioner University was not aware that GST was applicable on
affiliation fees and other related charges collected by it from its
affiliated colleges and was under the bonafide belief that like the
erstwhile Indirect Tax regime, affiliation services, being an integral
part of educational services, were exempted under the GST
regime as well.
3.15 Notwithstanding, the respondents issued the impugned show
cause notice dated 26.12.2023 under section 74 of the CGST, Act
alleging suppression of returns, non issuance of invoices and
willful evasion of tax even though petitioner had made full
payment of tax with interest.
3.16. Petitioner University requested vide its letter dated
25.01.2024 that its case should be considered under the
provisions of Section 73(5) of the CGST/RGST Act and accordingly
the penalty must be waived off as the tax liability along with the
applicable interest was paid even before the issuance of a show
cause notice. But to no avail.
3.17 Hence the writ petition before this court.
4. Before adumbrating further, for ready reference, we may first
note the applicable law which is as under :-
STATUTORY AND NOTIFICATION FRAMEWORK
4.1 It may be noted here that Under the CGST/RGST Acts, GST is
leviable only on “supply” of goods or services made for
consideration in the course or furtherance of business. Whereas,
Education services fall under Heading 9992 and are generally
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taxable at 18%, subject to exemptions under Notification No.
12/2017-CT dated 28.06.2017.
4.2. Entry 66 of Notification No. 12/2017 exempts services
provided by an educational institution to its students, faculty, and
staff; and services provided to an educational institution relating
to admission to, or conduct of examinations. By Notification No.
02/2018, the restriction “up to higher secondary” was removed,
extending the exemption to all levels of education. Notification No.
14/2018 further clarified that Central and State Educational
Boards are treated as educational institutions for the limited
purpose of conducting examinations.
4.3. With the aforesaid scheme in mind let us have a look at the
applicable provisions. Section 7 & 9 of the Central Goods and
Services Act, 2017, provides supply of goods and services
specified therein is subject to levy of service tax and levy of
collection taxes respectively. Sub section (1), (1-A), and (2) of
section 7 and sub section 3 and 4 of section 9, relevant to the
case, are reproduced below in extenso:
“ 7. Scope of supply .—(1) For the purposes of this Act, the
expression “supply” includes-
(a) all forms of supply of goods or services or both such as
sale, transfer, barter, exchange, licence, rental, lease or
disposal made or agreed to be made for a consideration by
a person in the course or furtherance of business;
(aa) the activities or transactions, by a person, other than
an individual, to its members or constituents or vice-versa,
for cash, for deferred payment or other valuable
consideration.
Explanation- for the purpose of this clause, it is hereby
clarified that, notwithstanding anything contained in any
other law for the time being in force or any judgment,
decree or order of any Court, tribunal or authority,
separate person and the supply of activities or
transactions inter se shall be deemed to take place from
such one person to another;
(b) import of services for a consideration whether or not in
the course or furtherance of business;
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(c) the activities specified in Schedule I, made or agreed to
be made without a consideration. []
[]*
(1A) where certain activities or transactions constitute a
supply in accordance with the provisions of sub-section
(1), they shall be treated either as supply of goods or
supply of services as referred to in Schedule II.
(2) Notwithstanding anything contained in sub-section (1),
(a) activities or transactions specified in Schedule III; or
(b) such activities or transactions undertaken by the
Central Government, a State Government or any local
authority in which they are engaged as public authorities,
as may be notified by the Government on the
recommendations of the Council, shall be treated neither
as a supply of goods nor a supply of services .
xxxx xxxxx xxxx
Schedule I, II, and III referred to in the aforesaid provisions are
not being referred or reproduced for sake of brevity as they are
not relevant for the adjudication of the controversy in hand. It
would be seen that, for invoking sub-clause (a) of sub-section (1)
ibid, the supply of goods and services has to be in the course or
furtherance of business.
4.4. Relevant of the Section 9, ibid is as under :-
9. Levy and collection.—
xxxx xxxxx xxxx
(3) The Government may, on the recommendations of the
Council, by notification, specify categories of supply of
goods or services or both, the tax on which shall be paid
on reverse charge basis by the recipient of such goods or
services or both and all the provisions of this Act shall
apply to such recipient as if he is the person liable for
paying the tax in relation to the supply of such goods or
services or both.
(4) The Government may, on the recommendations of the
Council, by notification, specify a class of registered
persons who shall, in respect of supply of specified
categories of goods or services or both received from an
unregistered supplier, pay the tax on reverse charge basis
as the recipient of such supply of goods or services or
both, and all the provisions of this Act shall apply to such
recipient as if he is the person liable for paying the tax in
relation to such supply of goods or services or both.”

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4.5. The word ‘business’ is defined in section 2 (17) of the Act as
under:
“ Section 2: In this Act, unless the context otherwise
requires . ----
xxxx xxxx xxxx
(
17) ―business includes-
(a) any trade, commerce, manufacture, profession, vocation,
adventure, wager or any other similar activity, whether or not it is for
a pecuniary benefit;
(b) any activity or transaction in connection with or incidental or
ancillary to sub-clause (a);
(c) any activity or transaction in the nature of sub-clause (a), whether
or not there is volume, frequency, continuity or regularity of such
transaction; (d) supply or acquisition of goods including capital
goods and services in connection with commencement or closure of
business;
(e) provision by a club, association, society, or any such body (for a
subscription or any other consideration) of the facilities or benefits to
its members;
(f) admission, for a consideration, of persons to any premises;
(g) services supplied by a person as the holder of an office which has
been accepted by him in the course or furtherance of his trade,
profession or vocation;
(h) activities of a race club including by way of totalisator or a license
to book maker or activities of a licensed book maker in such club; and
(i) any activity or transaction undertaken by the Central Government,
a State Government or any local authority in which they are engaged
as public authorities .”
4.6. The word ‘service’ is defined in section 2 (102) of the Act as
under:
“ Section 2: In this Act, unless the context otherwise
requires. ----
xxxx xxxx xxxx
(102) ―“services” means anything other than goods, money and
securities but includes activities relating to the use of money or its
conversion by cash or by any other mode, from one form, currency or
denomination, to another form, currency or denomination for which a
separate consideration is charged;
Explanation.–– For the removal of doubts, it is hereby clarified that
the expression ―services‖ includes facilitating or arranging
transactions in securities;”
4.7. The relevant of the statutory Notification No. 12/2017, dated
28.06.2017, issued by the Central Government, exempting from
Central the supply of certain services is as under:
“ In exercise of the powers conferred by a sub-section (3) and sub-
section (4) of section 9, sub-section (1) of section 11, sub-section (5)
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of section 15 and section 148 of the Central Goods and Services Tax
Act, 1017(12 of 2017), the Central Government, on being satisfied
that it is necessary in the public interest so to do , on the
recommendations of the Council, hereby exempts the intra-State
supply of services of description as specified in column (3) of the
Table Below from so much of the central tax leviable thereon under
sub-section 91) of section 9 of the said act, as is in excess of the said
tax calculated at the rate as specified in the corresponding entry in
column (4) of the said Table, unless specified otherwise, subject to the
relevant conditions as specified in the corresponding entry in column
(5) of the said Table, namely :-
SI.
No.
Chapter, Section,
Heading, Group
or Service
Code(Tariff)
Description of Services Rate
(percent)
Conditio
n
(1) (2) (3) (4) (5)
XXXX XXXX XXXX XXXX XXXX
66 Heading 9992 of
Heading 9963
Service Provided
(a) by an educational institution to its
students, faculty and staff;
(aa) by an educational institution by
way of conduct of entrance
examination against consideration in
the form of entrance fee;
b. to an educational institution, by way
of,-
(i)transportation of students, faculty
and staff;
(ii) catering, including any mid-day
meals scheme sponsored by the Central
Governments, State Government or
Union Territory
(iii)security or cleaning or house-
keeping services performed in such
educational institutions;
(iv) services relating to admission to, or
conduct of examination by, such
institution;
(v) supply of online educational
journals or periodicals:
Provided that nothing contained in sub-
items (I), (ii) and (iii) of item (b) shall
apply to an educational institutions
other than an institution providing
services by way of pre-school education
and education upto higher secondary
school or equivalent:
Provided further that nothing
contained in sub-item (v) of item (b)
shall apply to an institution providing
services by way of,-
(i) pre-school education and education
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up to higher secondary school or
equivalent; or
(ii) education as a part of an approved
vocational education course.
SUBMISSIONS ON BEHALF OF THE
PETITIONER/UNIVERSITY.
5. The activity of the Petitioner University does not fall
under the scope of supply under section 7 of the
CGST/SGST Act.
5.1 The petitioner, being a university established under a State
Act, does not qualify as “Government” or a “local authority”;
therefore, Section 2(17)(i) of the CGST Act, 2017 is inapplicable.
Further, its activities do not fall within the definition of “business”
under Section 2(17)(a)–(c). The petitioner’s educational activities
are non-commercial and do not constitute a “supply of services”
under GST. Imparting education cannot be regarded as “business”
under Section 2(17), as it does not involve trade, commerce,
manufacture, profession, vocation, or any similar commercial
pursuit.
5.2 The phrase “any other similar activity” is grammatically
linked only to “wager,” as indicated by the punctuation, and not to
the preceding terms. Section 2(17) defines “business” to include
trade, commerce, manufacture, profession, vocation, adventure,
wager, or similar activities, irrespective of pecuniary gain.
Education, by its nature, does not fall within these categories.
6. Affiliation fees are statutory fees and in the nature of
statutory/regulatory functions.
6.1 Fees, cess, or other amounts received by the petitioner, a
statutory university constituted under the Rajasthan Technical
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University Act, in the course of discharging its educational
functions, do not constitute “consideration” within the meaning of
Section 2(31) and therefore fall outside the scope of Section 7 of
the CGST Act.
6.2 Affiliation fees are statutory levies mandated under the
university’s governing statute, collected solely to regulate
academic standards, conduct examinations, and confer degrees,
functions performed in discharge of public duties without profit
motive or contractual character. Such collections do not satisfy the
“business” test under Section 2(17) of the CGST Act, as
educational regulation lacks commerciality, and the fees are
regulatory imposts rather than “consideration”, consistent with the
principle in Asst. CIT v. Ahmedabad Urban Development
1
Authority .
6.3 Income received from students, affiliated colleges, or other
sources incidental to the university’s core statutory functions
likewise cannot be subjected to GST on this basis.
6.4 The activities of the university are undertaken pursuant to
statutory obligations and are regulatory in nature, not commercial.
Consequently, as the activities do not constitute “business” and
the fees do not qualify as “consideration,” the charging provisions
under Section 9 read with Section 7 of the CGST/RGST Acts, 2017
are not attracted.
7. Notification No. 12/2017-CT(R) (as amended) dated
28.06.2017 Exempts Educational Services.
7.1 Without prejudice, even if affiliation were to be regarded as a
“service,” it is integrally connected with Entry 66 of Notification
1 (2023) 4 SCC 561.
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No. 12/2017-CT(R) (as amended) dated 28.06.2017, which
exempts services provided by an educational institution to its
students, faculty, and staff. Entry 66 of the Notification provides
that the services of the nature provided therein; shall be exempt
from the levy of GST. The entry is reproduced hereunder for ready
reference:
“
Services provided—
(a) by an educational institution to its students, faculty and staff;
(aa) by an educational institution by way of conduct of entrance
examination against consideration in the form of entrance fee;
(b) to an educational institution, by way of,-
(i) transportation of students, faculty and staff;
(ii) catering, including any mid-day meals scheme sponsored by the
Central Government, State Government or Union territory;
(iii) security or cleaning or house- keeping services performed in such
educational institution;
(iv) services relating to admission to, or conduct of examination by,
such institution;
(v) supply of online educational journals or periodicals:
Provided that nothing contained in sub-items (i), (ii) and (iii) of item
(b)] shall apply to an educational institution other than an institution
providing services by way of pre-school education and education up
to higher secondary school or equivalent:
Provided further that nothing contained in sub-item (v) of item (b)
shall apply to an institution providing services by way of,—
(i) pre-school education and education up to higher secondary school
or equivalent; or
(ii) education as a part of an approved vocational education course.”
7.2 Clause (a) of Entry 66.
Entry 66 exempts (i) services provided by an educational
institution to its students, faculty, and staff, and (ii) specified
services provided to an educational institution by third parties.
The University granting affiliation is itself an educational institution
and falls within the scope of the entry.
(i) “Educational institution” includes both universities and
affiliated colleges. Entry 66(a) identifies the recipients—students,
faculty, and staff—without restricting the nature of services; thus,
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its scope extends beyond pure teaching to include functions such
as affiliation.
(ii) The Petitioner University regulates admissions, conducts
examinations, prescribes curriculum and academic calendars,
maintains academic standards, and awards degrees. Students of
affiliated colleges are effectively university students; therefore,
affiliation is a service provided to students and is exempt from
GST.
7.3 Clause (aa) of Entry 66.
(i) The insertion of Entry 66(aa) exempting entrance
examinations reflects the legislative intent to include universities
within the exemption framework.
7.4 Clause (b)(iv) of Entry 66.
(i) The entry must be interpreted broadly, particularly because it
uses the expression “relating to,” which indicates a wide ambit
rather than a narrow construction, contrary to the approach
adopted in the impugned proceedings.
(ii) Judicial precedents have consistently held that phrases like
“relating to” or “in relation to” are words of wide amplitude and
not restrictive in scope (e.g., State Wakf Board, Madras Vs
2
Abdul Azee Sahib and Ors. ).
(iii) Accordingly, services connected with admission or conduct of
examinations must be given an expansive interpretation under
Entry 66.
(iv) University functions such as admission processes,
examinations, curriculum prescription, maintenance of standards,
2 AIR 1968 Mad 79
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and award of degrees are covered by Entry 66, with colleges
acting merely as facilitators; affiliation services are therefore
exempt.
(v) Since student admissions and eligibility depend on affiliation
granted by the University, affiliation is integral to the educational
process and qualifies as an exempt educational service.
(vi) As no institution can admit students or conduct examinations
without valid university affiliation, activities and fees relating to
affiliation fall within Entry 66 and are not liable to GST.
7.5 The Supreme Court and various High Courts, as held in the
Goa University vs. Joint Commissioner of Central Goods and
3
Services Tax. and Bengaluru North University vs. Joint
4
Commissioner of Central Tax, GST Commissionerate. , have
consistently adopted a broad interpretation of “education,”
drawing ratio inter alia from Sole Trustee, Lok Shikshana Trust
5 6
v. CIT. and T.M.A. Pai Foundation v. State of Karnataka. It
has been held that “education” encompasses activities relating to
imparting, regulating, and controlling education, including
affiliation, which is a prerequisite for admissions and examinations
under the university framework and operates for the benefit of
students of affiliated colleges as university students. Relevant
authorities are compiled at serial nos. 24 to 30 of the
case/provision compilation.
8. CBIC Circulars Ultra Vires
3 2025 SCC OnLine Bom 1262
4 WP No.5205/2024 Karnataka High Court
5 (1976) 1 SCC 254
6 (2002) 8 SCC 481
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8.1 CBIC - Tax Research Unit (TRU) has no statutory authority to
issue directions that effectively modify the CGST Act or confer
binding force on GST Council recommendations, which by
themselves do not have statutory effect; any such attempt is
impermissible in law.
8.2 Being a research and advisory wing, CBIC-TRU cannot
exercise quasi-legislative powers or issue instructions with tax
consequences. The impugned circular, by elevating GST Council
recommendations to binding norms, is therefore without
jurisdiction and arbitrary.
8.3 Subsequent CBIC Circulars, and the Press Note incorrectly
treat affiliation as a taxable “accreditation” service and seek to
curtail the exemption under Entry 66, and thus contrary to
Sections 7 and 9 of the CGST Act.
8.4 Attempt to impose tax obligations herein without any
legislative sanction, thus violating Article 265 (no tax without
authority of law) and Article 300A (no deprivation of property
without legal authority) of the Constitution, and are therefore ultra
vires.
8.5 It is settled law that circulars cannot override statutes,
impose a levy, or restrict exemptions, as held in CCE v. Ratan
7
Melting & Wire Industries. and Sandur Micro Circuits Ltd. v.
8
CCE.
9. Invocation of jurisdiction and imposition of penalty
under section 74 is erroneous and unfounded
7 (2008) 13 SCC 1
8 (2008) 14 SCC 336
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9.1 Section 74 of the RGST Act, 2017 can be invoked only where
tax has not been paid, short paid, erroneously refunded, or ITC
wrongly availed or utilized by reason of fraud, willful
misstatement, or suppression of facts with intent to evade tax.
9.2 The jurisdictional prerequisites for invoking Section 74 are:
(a) non-payment/short payment/erroneous refund or wrongful
ITC;
(b) presence of fraud, willful misstatement, or suppression; and
(c) intent to evade tax.
The proceedings under Section 74 are unsustainable unless these
ingredients are specifically alleged and established.
9.3 In the present case, no element of fraud, willful
misstatement, suppression, or intent to evade exists, as evident
from:
(a) The Petitioner’s bona fide belief that affiliation services were
exempt—consistent with the erstwhile service tax regime and
Entry 66 of Notification dated 28.06.2017—and the issue remains
contentious before constitutional courts.
(b) Full cooperation with departmental inquiries and timely
submission of all information sought.
(c) Voluntary payment of ₹4,25,86,142/- towards GST and
₹3,02,68,940/- towards interest prior to issuance of the impugned
SCN.
(d) No GST was collected from affiliated colleges; tax and interest
were discharged from the Petitioner’s own funds.
9.4 These facts demonstrate bona fide conduct and negate any
intent to evade tax. Accordingly, invocation of Section 74 is
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without jurisdiction, and the impugned SCN and demand are liable
to be set aside for failure to establish the statutory conditions.
9.5 The Petitioner, a statutory university established under the
Rajasthan Technical University Act, 2006 to advance technical
education and public objectives, functions as an instrumentality of
the State. It is inherently implausible that such a body would
deliberately evade tax, particularly where doing so would
undermine public revenue—reinforcing the absence of mens rea.
10. Even arguendo if GST is leviable the
affiliated/constituent colleges are liable to pay the GST
along with interest and penalty.
10.1 The University has deposited the GST and applicable interest
pursuant to demands raised by the GST Department; any recovery
from constituent colleges is consequential and not arbitrary. As a
State-run institution, the University acts in discharge of public
functions and in compliance with governmental directions.
10.2 By letters dated 24.11.2020, 12.11.2021, and 26.11.2022,
issued while calling for affiliation/renewal fees, the University
expressly notified affiliated colleges that GST at applicable rates
(including 18%) would be charged on affiliation, variation,
inspection, NOC, and related fees as per government directions,
thereby placing them on notice.
10.3 Accordingly, affiliated colleges were fully aware that GST
could become payable upon renewal of affiliation and cannot now
claim surprise or arbitrariness. GST, being an indirect tax, is
economically borne by the recipient of the supply; therefore, if
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held leviable, the incidence properly falls on the constituent
colleges.
11. CASE LAW RELIED BY THE PETITIONER -
a. Goa University vs. Joint Commissioner of Central
9
Goods and Services Tax.
b. Bengaluru North University vs. Joint
10
Commissioner of Central Tax, GST Commissionerate.
c. Principal Additional Director General, DGGSTI vs.
11
Rajiv Gandhi University of Health Sciences.
d. Principal Additional Director General, DGGSTI vs.
12
Rajiv Gandhi University of Health Sciences.
e. M/s Doypack Systems Pvt. Ltd. Vs. Union of India
13
&Ors.,
f. Renusagar Power Co. Ltd. Vs. General Electric
14
Company &Anr.,
g. Coca Cola India (P.) Ltd. Vs. Commissioner of
15
Central Excise, Pune III.
h. Commissioner of Central Excise & Customs vs.
16
Parth Poly Wooven (P.) Ltd
i. State Wakf Board, Madras Vs Abdul Azee Sahib
17
and Ors.
SUBMISSIONS ON BEHALF OF THE RESPONDENTS.
12. Affiliation is the formal grant by the University admitting a
college to its privileges upon fulfillment of prescribed statutory
9 2025 SCC OnLine Bom 1262
10 WP No.5205/2024 Karnataka High Court
11 (2025) 32 Centex 526 (Kar.)
12 WA No.856/2022 Karnataka High Court
13 (1988) 2 SCC 29
14 (1984) 4 SCC 679
15 Central Excise Appeal No.118/2007 Bombay High Court
16 Tax Appeal No.1704/2010 Gujarat High Court
17 AIR 1968 Mad 79
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conditions. Affiliation charges are prerequisites for enabling
colleges to admit students and run courses and are distinct from
fees collected by colleges from students. While tuition and
examination fees collected from students are exempt under
Notification No. 12/2017-CT (Rate) dated 28.06.2017 , affiliation
services provided by the University to colleges are not covered by
the exemption and are therefore taxable.
12.1 Notification exempts specified services provided by
educational institutions to students, faculty, and staff, and certain
services provided to educational institutions (such as
transportation, catering, security, housekeeping, admission,
examination, and supply of journals). Affiliation services are not
included in the exempted categories and hence remain taxable.
12.2 The exemption framework by Notification, limits exemptions
for higher educational institutions to specific entries—namely
clauses (a), (aa), and sub-items (iv) and (v) of clause (b) under
Serial No. 66—none of which cover affiliation.
12.3 The GST Council, after deliberation, chose to exempt services
directly connected with students (e.g., transport, catering,
admission, examinations). Services relating to recognition or
regulatory oversight of colleges, such as affiliation, were not
exempted. Entry 66(b)(iv) specifically covers services relating to
admission or conduct of examinations, not affiliation.
12.4 Under Section 2(102) of the CGST Act, “services” include any
activity other than goods, money, or securities. Grant of affiliation
for consideration qualifies as a supply of service classifiable under
Heading 9992 (Education Services) and is taxable at 18% under
Notification No. 11/2017-CT, ibid . Clarification issued following the
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GST Council’s deliberations expressly state that affiliation services
provided by universities to colleges are not covered by the
exemption under Notification No. 12/2017-CT.
12.5 Exemption notifications must be strictly construed according
to their text and legislative intent; no benefit can be claimed
unless the case clearly falls within the specified conditions. Courts
cannot expand exemptions by implication. The exemption must be
analyzed with reference to the parties to the transaction. While
services between colleges and students may qualify as exempt
educational services, the transaction here is between the
University and the college, which falls outside the exemption.
12.6 The contention that GST on affiliation ultimately burdens
students is irrelevant, as exemption depends on the nature of the
supply, not its economic incidence; student-facing fees are already
exempt.
12.7 Accepting a broad interpretation would render the exemption
otiose by allowing all activities connected to education (e.g.,
construction, procurement) to claim exemption. Therefore, the
notification must be applied as written. Since affiliation is not
expressly exempt, consideration for affiliation services attracts
GST, and any exemption cannot be inferred in the absence of
explicit statutory provision.
13. JUDGMENTS RELIED UPON :
i. Commissioner of Customs (Import), Mumbai Vs
18
Dilip Kumar and Company and Ors.
18 Civil Appeal No.3327/2007 SC
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ii Krishi Upaj Mandi Samiti, New Mandi Yard, Alwar
Vs. Commissioner of Central Excise and Service Tax,
19
Alwar.
iii Care College of Nursing and Ors. Vs. Kaloji
20
Narayana Rao University of Health Sciences and Ors.
14. In the aforesaid backdrop of the rival contentions we shall
now proceed to render our opinion by recording discussion and
upon analysis of the applicable law.
ISSUES FOR DETERMINATION
15. The following issues arise for consideration:
(i) Whether grant of affiliation by a University constitutes a
“supply of service” under Section 7 of the CGST Act, 2017?
(ii) Whether affiliation fees can be regarded as “consideration”
for such alleged supply?
(iii) If affiliation is assumed to be a service, whether it is exempt
under Entry 66 of Notification No. 12/2017-CT (Rate)?
(iv) Whether levy of GST on affiliation fees is legally sustainable?
DISCUSSION AND ANALYSIS
16. Affiliation to the University is the sine qua non for the
Colleges to admit the students to University classes, impart
education to them, and the taking of the examinations and
obtaining of University degrees by the students. Affiliation is thus
an essential and integral part of imparting of education. It is not a
‘business’ as defined in sub-section 17 of section 2 reproduced
above. The element of ‘in the course or furtherance of business’ is
19 2022 SCC OnLine SC 224
20 WP No.34617/2022 Telangana High Court
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the sine-qua non for applicability of sub-clause (a), sub-section
(1) of section 7 ibid, which does not exist in the present case.
17. University affiliation is a statutory and regulatory function,
intrinsically connected with admission of students, imparting them
education, their taking the examination, and conferment of
University degrees. Colleges are merely recipient of the affiliation;
act as facilitators or extended arms for imparting University
education to the students, while the real beneficiaries of affiliation
are students, who are ultimately conferred degrees by the
University.
18. It is also pertinent to note that vide section 2 of the
Rajasthan Technical University Act, 2006, ‘affiliated college’ means
a college or institution which has been granted affiliation to the
University. Under section 4, the objects of the University include
the promotion of better interaction and co-ordination among
different universities and colleges, to improve the governance and
facilities for technical education, etc. Section 5 provides that the
University shall have the powers, inter alia, to hold examinations,
institute and award degrees, lay down conditions for affiliation of
course and colleges, to rescind affiliation. Grant/obtaining of
affiliation is a statutory mandate.
19. Thus, the grant of affiliation is a statutory function, enabling
the University to discharge its core mandate of imparting
education through affiliated colleges. It is non-negotiable and
devoid of quid pro quo. Affiliation fees charged by the University
from the Colleges is a compulsory statutory levy and not in the
nature of “consideration” for supply of a service.
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20. We, therefore, hold that sub-clause (a) of sub-section (1) of
section 7 ibid is not attracted to the function of grant of affiliation
on charging of fee by the University.
21. Learned counsel for respondents pointed out that there are
no words in clause (aa) of the sub-section (1) ibid to show that
the activities and transactions mentioned therein have to be in the
course or furtherance of business. On that basis, it is strongly
argued that, even in the absence of element of ‘furtherance of
business’, the charging of affiliation fee by the University from
colleges would be covered by clause (aa) of the sub-section (1)
ibid and be subject to levy of service tax. We are unable to accept
the contention.
22. As observed above, the categorical mandate of clause (a),
sub-section (1) of section 7 ibid is that, for the purpose of levy of
tax, the supply of service must be ‘in the course or furtherance of
business’. As against this, of course, there are no words in clause
(aa) of the sub-section (1) ibid to show that the activities and
transactions mentioned therein have to be in the course or
furtherance of business.
23. Clause (aa), if so read narrowly and in isolation from the
aforesaid remaining provisions of Section 7 would be obviously
contradictory to and destructive of clause (a) and lead to
absurdity. While the categorical mandate of sub-clause (a), sub-
section (1) of Section 7 ibid is that, for the purpose of levy of tax,
the supply of service must be ‘in the course or furtherance of
business’. As against this, clause (aa), if read narrowly and in
isolation from the aforesaid remaining provisions of Section 7 (a)
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would attract liability for service tax even if the activities and
transactions mentioned in clause (aa) are otherwise than ‘in the
course or furtherance of business’.
24. We are of the considered opinion that a purposive and
harmonious construction of these two apparently divergent sub-
clauses has to be attempted by adopting the doctrine of ejusdem
generis. Accordingly, we now proceed for that exercise.
25. In the ‘introduction’ to ‘statement of objects and reasons’ of
the Central Goods and Services Tax Bill, culminating into the 2017
Act, it is mentioned that ‘the Bill proposes a single tax to be levied
on supply of goods and services or both at each stage of supply
chain, ranging from manufacture or import to the retail level. It
will broaden tax base as well as improve compliance. It provides
for anti-profiteering clause to ensure that the business passes on
the benefit of reduced tax incidence on goods and services or both
to the consumers. An overall reading of the introduction and
statement of objects and reasons of the Bill seems to show that
the Act is intended primarily to rationalize the tax on business,
trade, commerce, manufacturing, or activities of commercial
character.
26. By resorting to an attempt at purposive and harmonious
construction of these two apparently divergent sub-clauses, i.e.,
(a) and (aa), we are inclined to hold that the requirement of ‘in
the course or furtherance of business’ is implicit for the activities
and transactions mentioned in clause (aa) for attracting liability to
tax. This being so, it follows that the aforesaid other observations
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against applicability of clause (a) would equally apply against
applicability of clause (aa), sub-section (1) of section 7.
27. As a result, it is held that sub-clause (aa) of sub-section (1)
of section 7 ibid is also not attracted for the levy of tax on fee
charged by the University from the Colleges for grant of affiliation.
28. Adverting now to Notification No. 12/2017, dated
28.06.2017, issued by the Central Government, exempting from
Central the supply of certain services. The notification issued
under Sections 9, 11, 15 and 148 of the CGST Act is a beneficial
exemption intended to keep core educational functions outside the
GST net. Entry 66 reflects the legislative intent to protect the
entire educational ecosystem, including its regulatory and
academic framework, recognizing education as a public function
rather than a commercial activity. Entry 66, covering services
under Heading 9992, must be construed purposively to include all
activities integrally connected with imparting and administering
education, extending beyond classroom teaching to the
institutional mechanisms through which education is delivered.
28.1. Clause (a) thereof broadly exempts services provided by an
educational institution to its students, faculty, and staff without
restricting the nature of services. Functions performed by a
university that ultimately benefit students i.e. affiliation, which
enables admission, examination, and conferment of degrees are,
therefore, covered. Clause (aa), exempting entrance
examinations, confirms that procedural and regulatory activities
forming part of the academic continuum fall within the exemption,
supporting a broad reading that encompasses affiliation. Clause
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(b)(iv) exempts services “relating to admission to, or conduct of
examination.” Given the wide import of “relating to,” affiliation
being the foundational requirement for admissions and
examinations, the same falls within this ambit.
28.2. Affiliation is a statutory regulatory function to maintain
academic standards and integrate colleges into the university
system; it is inseparable from the educational process and cannot
be treated as an independent commercial supply. The scheme of
Entry 66 shows an intent to exempt essential institutional
processes that enable education. Excluding affiliation would defeat
the purpose of keeping education tax neutral. The provisos do not
exclude affiliation, and in the absence of express exclusion, a
harmonious and purposive interpretation requires that it be
treated as exempt to advance the object of promoting education.
Accordingly, it so appears that affiliation services, being integral to
admissions, examinations, and conferment of degrees, are
covered by Entry 66.
29. Thus we hold that affiliation being inseparably linked to
admission of students to courses, conduct of examinations, and
the award of degrees, it squarely falls within the exemption Entry
66 of Notification No. 12/2017, dated 28.06.2017. Vide the said
notification, services provided: (a) by an educational institution to
its students, faculty, and staff; …(b) to an educational institution
by way of … (iv) services relating to admission to, or conduct of
examination by such institution, are exempt from the levy of
service tax.
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30. Furthermore, relevant Sections 7 and 9 (liability and levy tax
on supply of goods and services) of the Central Goods and
Services Act, 2017, came into force from 01.07.2017. The
exemption position under Notification No. 12/2017, dated
28.06.2017, is a continuation of the pre-July, 2017 regime.
Thereunder, affiliation fees was exempted from and was not
subject to tax. Thus, argument to the contrary, as canvassed by
the respondents that Entry 66 of Notification No. 12/2017 does
not expressly exempt affiliation services and must be interpreted
strictly, is rejected in light of the discussion in the preceding part.
31. Circulars or executive clarifications cannot override statutory
provisions or exemption notifications. In the face of statutory
exemption from tax in respect of specified services, as provided
vide Notification No. 12/2017, dated 28.06.2017, the reliance on
CBIC Circular letter No. 151/07/2021-GST dated 17.06.2021,
clarifying that services such as affiliation and accreditation are
taxable, is also misplaced.
32. Reliance has also been placed by respondents on the DB
21
judgment of Delhi High Court in NBEMS Vs. Union of India . In
that case, the challenge was to Notification No. 12/2017, dated
28.06.2017, laying down that the services rendered by such State
or Central Boards (like the petitioner), such as providing
accreditation to an institution or to a professional [accreditation
fee such as fee for Foreign Medical Graduate Examination (FMCG)
screening test], would be chargeable to GST. It was held in that
case that the services provided by the petitioner for conducting
21 2024 SCC OnLine Delhi 3029
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screening test and the fee charged for accrediting medical
institutions does not fall within the scope Serial No. 66(a) and
Serial No. 66(aa) of the 2017 notification and that the petitioner
was snot exempted from the payment of GST in respect of said
services by virtue of the aid notification.
32.1 It was noted by Delhi High Court that screening tests are not
conducted as a part of the curriculum; the said tests are also not
in the nature of entrance examinations but for the purpose of
recognizing primary medical qualifications secured by candidates
from institutions abroad; the accreditation fee is charged from
medical institutions for accrediting them; these services are not
covered under the 2017 notification and that the candidates
appearing for the screening tests are not students of the
petitioner. There are no such facts and circumstances in the
present case. The said judgment is, therefore, not applicable and
does not help the respondents in the instant case.
33. Affiliation of a college with a university and accreditation of a
college or university are conceptually and legally distinct
processes, though both operate within the broader framework of
higher education governance. Affiliation refers to a formal and
statutory relationship established between a college and a
university, whereby the university grants the college the authority
to conduct courses of study prescribed by it, admit students to
those courses, and present them for university examinations. In
essence, affiliation is the legal mechanism that integrates a
college into the academic and examination system of the
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university, enabling the university to confer degrees upon students
studying in the affiliated college.
34. Moreover, accreditation, by contrast, is a process of quality
assessment and assurance carried out by specialized external
bodies such as the National Assessment and Accreditation Council
(NAAC) or the National Board of Accreditation (NBA), functioning
under the broader regulatory framework of the University Grants
Commission. The purpose of accreditation is not to create a legal
relationship permitting the institution to function, but rather to
evaluate whether the institution meets prescribed standards in
respect of teaching, infrastructure, governance, research, student
support, and outcomes. Accreditation culminates in the award of a
grade or status that reflects the quality of the institution.
34.1. The fundamental difference lies in their purpose and legal
effect. Affiliation is a mandatory precondition for a college to
operate lawfully and to offer recognized degree programmes under
a university. Without affiliation, a college cannot admit students to
university courses or present them for examinations, and any
degrees purportedly awarded would lack legal validity.
Accreditation, on the other hand, is not a condition precedent to
existence; an institution may function if duly affiliated even
without accreditation, although it may face limitations in accessing
grants, autonomy, or reputational advantages. Another important
distinction concerns the nature of control exercised.
34.2. Through affiliation, the university exercises academic and
administrative oversight over the college, including approval of
courses, adherence to curriculum, conduct of examinations, and
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compliance with statutory regulations. The affiliated college
operates, in effect, as an academic extension of the university.
Accreditation bodies, however, do not exercise day-to-day control;
they periodically assess the institution through peer review and
performance metrics, focusing on continuous improvement rather
than direct governance.
34.3 Affiliation is typically granted and renewed in accordance
with the statutes or regulations of the university and may involve
periodic inspections to ensure compliance with prescribed norms.
Withdrawal of affiliation has serious consequences, potentially
disabling the college from continuing its academic programmes.
34.4 Accreditation, in contrast, is granted for a fixed cycle and
results in a quality grade; failure to secure or maintain
accreditation affects credibility and eligibility for certain benefits
but does not automatically terminate the institution’s operations.
34.5. To sum up, affiliation operates in the domain of legality and
academic authorization, establishing the formal link that allows a
college to participate in the university’s educational system.
Accreditation operates in the domain of quality assurance,
providing an evaluative judgment on the standards maintained by
the institution. While both mechanisms are important for the
proper functioning and credibility of higher education institutions,
they serve different purposes and are not interchangeable.
35. Our view that affiliation is integral to education and affiliation
fee is exempt from tax, is also supported by judgments rendered
by other High Courts in:-
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22
(i) Madurai Kamaraj University v. Joint Commissioner ,
“
19. In this context, sub-clause (iv) of clause 9, referred to above, is
so important, which says that services related to admission or
conduct of examination by such institution are exempted services.
Here, the services rendered to admission is two fold, one is the
admission being made for the students in a particular institution.
However, such admission can be made legally by the said institution
only on the basis of the affiliation granted by the University, fixing
the intake strength of each and every course for the particular
academic year. Illustratively, if there is a class where the university
has given permission/affiliation for 100 students, not even 101
students can be admitted by the college. Therefore, that admission of
the students strictly relates to the affiliation granted by the university.
Therefore, the affiliation activity is an integral part of imparting
education for any student for getting qualified to get a qualification
like degree or diploma. Accordingly, the services provided by the
educational institution like the petitioner institution, i.e., the
university, to give affiliation can be an integral part of the
educational services being provided jointly, both by the University
and the college. The college cannot independently function without
the affiliation of the university. Therefore, for the purpose of
providing the services of education, both the university as well as the
college concerned, who get affiliated to the university, cannot be
separated.
20. This is the purposive interpretation which is only possible
because the services relating to admission and also the conduct of
examination by such institution has been exempted. When we talk
about the conducting of examination, it is the vehement contention of
the revenue, as submitted by the learned Standing Counsel by relying
upon the advance ruling referred to above, stating that exempted
service on the conduct of examination is that it relates to admission to
institution and anything related to examination, based on which
degree, title, or diploma is conferred to the students.
21. With respect, this Court is of the concerned view that that kind of
narrow or pedantic interpretation cannot be possible in the words
“conduct of examination”. The reason being, the very prime function
of the petitioner university under the statute, under which it has been
created, under Section 4(4) of the University Act, which has been
quoted herein above, is to hold examinations and to confer degrees,
titles, diplomas, and other academic distinctions. Therefore, holding
or conducting an examination is primarily a job of the university, and
the colleges affiliated to the university are only facilitators.
Therefore, examinations are not conducted directly by the colleges, it
is being conducted by the university, but the facilitator is the college.
Therefore, the word “conduct of examination by such institution”
means conduct of examination by the university and the college and
not by the college alone. The examination is the examination of the
university, for which facilitation is given by the college, wherein the
examinations are conducted and ultimately valuation is to be done by
the university and marks are awarded and degree is conferred by the
university. Therefore, it is the university where the facilitator is the
college, where the examination is being taken place, and therefore the
word “conduct of examination” cannot have such a narrow and
pedantic interpretation as has been given by the Advance Ruling
22 WP (MD) No.20502/2019, Madras High Court
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Authority in their order dated 19.11.2020, which has been, in fact,
heavily relied upon by the respondent revenue. Therefore, this Court
is not subscribing the said view given by the Advance Ruling
Authority in their order dated 19.11.2020. ”
(ii) Manonmaniam Sundaranar University v. Joint Director
23
(GST Intelligence).
“ 7. Be that as it may, the fee collected by the petitioner will be in the
nature of compulsory levy, as per the provisions of the relevant
statute. The petitioner University was established by legislation.
Section 24(16) of the said statute enables the Syndicate of the
University to prescribe the fees to be charged for the approval and
affiliation of colleges, for admission to the examinations, degrees,
titles, and diplomas of the University, for the registration of
graduates, for the renewal of such registration, and for all or any of
the purposes specified in Section 4.
8. There can be no doubt that a college, as per the UGC regulations,
will have to be affiliated to some University. Therefore, the affiliation
fees, as well as the inspection commission collected by the University,
are in the nature of statutory levies. By performing those activities, the
petitioner is only discharging a statutory function, and the fees
collected by the petitioner cannot be amenable to e to levy of Service
Tax.
9. However, the demand of the respondents with regard to renting of
immovable property will stand on a different footing. The learned
counsel appearing for the petitioner draws my attention to Section
4(18) of the Act to sustain the contention that the petitioner was only
discharging statutory function.
10. I am unable to accept the said proposition. It is true that
authorisation is given to the University to maintain the property. But
then, there is clear commercial element in these transactions. The
University is renting the property to other institutions and collecting
rent from them. Therefore, the second respondent was justified in
raising demand for the said service. However, there is no justification
in levying penalty. The assessee is not a private entity. The
respondents do not allege forgery or misrepresentation. I sustain the
impugned order in so far as the demand for payment of Service Tax on
renting of immovable property is concerned. In all other respects, it is
quashed. The writ petition is partly allowed. No costs. Consequently,
connected miscellaneous petitions are closed .”
(iii) Goa University vs. Joint Commissioner of Central Goods
24
and Services Tax.
“ 35. Let us turn to the present case. The Petitioner University is
established under a statute, namely the Goa University Act, 1984,
with the purpose of ensuring proper and systematic instruction,
teaching, training, and research. The fees, such as affiliation fees,
prospectus fees, migration certificate fees, sports fees, etc., received
by the Petitioner are per se not commercial in nature. The State has a
23 WP (MD) No.12879/2019, Madras High Court
24 2025 SCC OnLine Bom 1262
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duty to provide education to the people of India, and this duty is being
discharged through the University.
36. We have already noticed the requirements of Section 7 of the
CGST Act. Section 2(31) of the CGST Act defines the phrase
“consideration,” whereby money or money value, in respect of or in
response to a supply, would qualify as consideration. In our opinion,
affiliation is undertaken by the University in terms of statutory
requirements and in discharge of public functions; therefore, the fee
collected for affiliation fails to qualify as “consideration.” The fees
collected by the University, i.e., affiliation fees, PG registration fees,
and convocation fees, are not amenable to GST, as the fees are
statutory or regulatory in nature and not contractual. The same
cannot be given the colour of commercial receipts, as there is no
element of commercial activity involved in the subject transaction. In
Assistant Commissioner of Income Tax (Exemptions) v. Ahmedabad
Urban Development Authority (supra), Para 160 held as follows:
“Fee, cess and any other consideration’ has to receive a
purposive interpretation in the present context. If a fee, cess, or
such consideration is collected by a State department or
statutory entity in furtherance of its mandate, such collection
cannot be treated as consideration towards trade or business.
Therefore, regulatory activity necessitating the collection of fees
or cess in terms of enacted law, or collection of amounts in
furtherance of activities such as education, regulation of
professions, etc., are per se not business or commercial in
nature… [text retained as provided].”
37. The concept of consideration involves an element of contractual
relationship, wherein the person undertaking the activity of supply
does so at the desire of another in exchange for consideration,
involving a quid pro quo. In our opinion, the fee collected for
affiliation will not qualify as consideration, since neither quid pro quo
is involved nor is it a contractual obligation. In Principal Addl.
Directorate General DGGSTI v. Rajiv Gandhi University of Health
Sciences (supra), the Karnataka High Court in Para VIII held as
follows:
“Affiliation creates a kind of umbilical cord between the
affiliating body and the affiliated entity… [text retained as
provided with minor grammatical corrections] … In view of all
this, the Revenue is not justified in levying Service Tax on the
income accruing to the University on account of affiliation…
The periodicity of collection of affiliation-related fees pales into
insignificance.”
38. The Petitioner is actively involved in imparting education to
students and acts as a regulator of education. It is by virtue of the
affiliation granted by the Petitioner University to constituent colleges
that such colleges conduct programmes of study. The activities
undertaken by the Petitioner University are statutory and regulatory
in nature.
39. The High Court of Madras in Manonmaniam Sundaranar
University v. The Joint Director (GST Intelligence), 2021-TIOL-888-
HC-MAD-ST, held that affiliation fees, as well as inspection
commissions collected by the University, are statutory levies. It was
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held that, by performing such activities, the Petitioner is only
discharging a statutory function and the fees collected are not
amenable to Service Tax. From a conjoint reading of the statutory
provisions and judicial precedents, the fees collected by the Petitioner
University under statutory mandate for regulating affiliated colleges
cannot be brought within the GST net.
40. We are in respectful agreement with the Karnataka High Court in
Rajiv Gandhi University of Health Sciences (supra), which held that
a University granting affiliation is also an educational institution.
The Madras High Court in Madurai Kamaraj University v. Jt. Comm
of GST & C.Ex., Madurai [(2021) 54 GSTL 385 (Mad.)] held that the
term “educational institution” includes not only affiliated colleges
but also the University itself. Even assuming that affiliation fees
constitute a service, such services would fall within the exemption
entry, as students of affiliated colleges are ultimately students of the
University that grants the degree.
41. Without affiliation from the Petitioner University, constituent
colleges are not permitted to admit students for courses. Further,
examinations are conducted by the Goa University, leading to the
award of degrees. Hence, the fees collected from colleges are covered
by the exemption notification. The activity of collecting affiliation
fees is exempt from GST and is therefore not liable to tax.
42. Goa University is actively involved in imparting education and
regulating education. Section 24 of the Goa University Act empowers
the University to frame ordinances relating to admission, enrolment,
and fees for admission and examination. Affiliation forms the basis
upon which affiliated colleges conduct courses, examinations, and
degree-awarding processes. The term “education” should not be
narrowly restricted to classroom instruction; rather, it includes
curriculum design, affiliation to maintain educational standards, and
conferral of degrees.”
36. To support tax ability of affiliation fees, the respondents have
25
relied upon Advance Ruling in Bharathiar University , vide which
the composite supply comprising sale of application forms, course
registration, inspection, and related charges were held to be not
exempt under Sl. No. 66 of Notification No. 12/2017-C.T. (Rate),
dated 28.06.2017.
37. Reliance is also placed by respondents on a judgment of the
Telangana High Court in Care College of Nursing vs. Kaloji
Narayana Rao University of Health Sciences (supra) .
However, in our view, the same do not advance their case in any
manner.
25 Authority for Advance Ruling, Tamil Nadu
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38. In Care College of Nursing , a Division Bench of the
Telengana High Court observed that, since the inspection and
affiliation fee charged by the respondent University from the
affiliated colleges had not been specifically exempted from tax, the
benefit of exemption under Notification No. 12/2017, dated
28.06.2017, could not be extended to the petitioners.
38.1 With utmost respect to the learned Division Bench, we are of
the opinion that a perusal of Notification No. 12/2017, dated
28.06.2017, in background of aforesaid fact situation, leaves no
manner of doubt that the grant of affiliation by the University to
it’s constituent colleges clearly falls within the scope exemption
under Entry 66 of Notification No. 12/2017, dated 28.06.2017, the
same being services provided (a) by an educational institution to
it’s students and (b) to an educational institution by way of …(iv)
services relating to admission to, or conduct of examination by
such institution. The preceding words ‘relating to’ are significant
and show that the import of relevant entry is wide and
comprehensive and not narrow or restrictive.
39. In Goa University vs. Joint Commisioner (supra) , a
Division Bench of the Bombay High Court noted that, without the
affiliation from the petitioner University, the constituent colleges
are not permitted to admit students for the courses. Further, the
examination is conducted by the Goa University, which in turn
leads to award of degree to the students. It was held that, hence,
the fee which are collected from the colleges are clearly covered
by the Entry No. 66 of the exemption notification No. 12/2017-
CT(R), dated 28.06.2017, and the activity of the Goa University in
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collecting the affiliation fee is exempt from GST and hence the
fees collected by the Goa University is not liable to tax. The
situation in the present case is analogous. We are in respectful
agreement with the aforesaid view taken by the learned Division
Bench of the Bombay High Court. Accordingly, we hold that the
activity of the petitioner University in collecting the affiliation fee
is exempt from GST and hence the affiliation fees collected by the
petitioner University is not liable to tax.
40. Before concluding, there is another aspect of the matter
which deserves to be noted i.e. demand for tax has been raised by
the respondents against the petitioner University (paid
substantially, though under protest). Obviously, the petitioner is
an aggrieved party, entitled to challenge the legality of demand.
Merely because the liability, if any, for payment of tax on affiliation
fee would/could ultimately fall on the shoulders of the concerned
colleges, that does not negate the locus standi of the petitioner to
challenge the demand. We, therefore, reject the contention of the
respondents that the petitioner has no locus standi to file the writ
petition challenging the legality of demand.
SUMMARY
41. Affiliation is a statutory and regulatory function intrinsically
connected with imparting education, conduct of examinations, and
conferment of degrees, and does not amount to a commercial
activity. Colleges merely act as facilitators or extended arms of the
University; the real beneficiaries of affiliation are students, who
are ultimately conferred degrees by the University.
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41.1. Affiliation is a mandatory, non-negotiable, and devoid of
quid pro quo; hence, affiliation fees are a compulsory statutory
levy and not “consideration”.
41.2. We are thus unable to persuade ourselves with the stand
taken by the respondent that affiliation is a distinct service
rendered by the University to colleges for consideration and is
taxable at 18% under Heading 9992. Even assuming affiliation to
be a service, it squarely falls within the exemption under Entry 66,
being inseparably linked to admission and conduct of
examinations. The exemption position under GST is a continuation
of the pre-GST service tax regime, under which affiliation fees
were never subjected to tax.
41.3. Hence, argument to the contrary, as canvassed by the
respondents that Entry 66 of Notification No. 12/2017 does not
expressly exempt affiliation or accreditation services and must be
interpreted strictly, is rejected in light of the discussion in the
preceding part.
FINDINGS
42. Issue (i): Whether Grant of Affiliation is a Supply of Service-
Section 7 of the CGST Act contemplates supply only when an
activity is carried out in the course or furtherance of business.
Grant of affiliation is a statutory function enabling the University
to discharge its core mandate of imparting education through
affiliated colleges. Applying the doctrine of ejusdem generis to
Section 2(17), affiliation cannot be equated with trade, commerce,
or any activity of commercial character. Accordingly, we hold that
grant of affiliation does not constitute a “supply of service”.
42.1. Issue (ii): Whether Affiliation Fees Constitute Consideration-
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Affiliation is compulsory for colleges; there is no element of
choice, bargaining, or reciprocity. The fee is a statutory levy, not a
payment for a negotiated service. We thus hold that in absence of
quid pro quo, the essential element of “consideration” is missing.
42.2. Issue (iii): Applicability of Exemption under Entry 66.
Even assuming affiliation to be a service, it is inseparably
connected with: curriculum approval, admission of students,
conduct of examinations, and conferment of degrees. Students
admitted through affiliated colleges are, in law, students of the
University. We hold that entry 66 must be interpreted purposively
to cover services forming the backbone of educational delivery,
including affiliation.
42.3. Issue (iv): Validity of GST Levy :-
Circulars or executive clarifications cannot override statutory
provisions or exemption notifications. Levy of GST on affiliation
fees results in indirect taxation of education, which is
impermissible. We hold that the impugned levy is therefore
without authority of law.
CONCLUSION
43. As an upshot of the what is reasoned and discussed in the
preceding part, it is held that grant of affiliation by a University is
a statutory and regulatory function and does not constitute a
supply of service under the CGST Act. Affiliation fees are not
consideration for any taxable activity. Even otherwise, affiliation
services are exempt under Entry 66 of Notification No. 12/2017-
CT (Rate). Levy and collection of GST on affiliation fees is illegal
and unsustainable.
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44. Before we part, though we have already opined as above, but
it bears reiteration, notwithstanding the views already recorded,
that under the Affiliation Bye-laws of the Central Board of
Secondary Education, “affiliation” is expressly understood as an
institutional arrangement enabling a school to prepare its students
for admission to the Board examinations. A careful reading of the
Bye-laws makes it abundantly clear that the conditions governing
affiliation of schools with the Board are, in substance and effect,
pari materia with those governing affiliation of colleges with a
university. These conditions include adherence to the prescribed
curriculum, maintenance of academic and infrastructural
standards, and presentation of students for evaluation by the
examining body.
44.1. Pertinently, by Revenue Notification No. 14/2018 dated
26.07.2018, a clarification was introduced in the parent
Notification No. 12/2017 whereby Central and State Educational
Boards were deemed to be “educational institutions” for the
limited purpose of providing services by way of conduct of
examinations to students.
45. Thus, in this backdrop, any attempt to deny universities
similar treatment at par with Central and State Educational Boards
is manifestly arbitrary and ex facie discriminatory, particularly
when universities equally discharge the function of conducting
examinations for students of affiliated colleges as an integral step
towards conferment of degrees.
46. Consequently, aside all above, for this reason too, the so-
called service of affiliation rendered by a university to its affiliated
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colleges squarely falls within the ambit of exempt services under
Entry 66(a) as well as Entry 66(b)(iv).
RELIEF
47. D.B. CWP No.9556/2024 and all other writ petitions as per
Appendix ‘A’ are allowed. Proposed levy and demand of GST on
affiliation fee is held to be unsustainable in law. Impugned show
cause notice dated 26.12.2023 issued by Office of Commissioner,
Central Excise & CGST Commissionerate is quashed. It is also
directed that subject to the verification that the burden of the GST
on affiliation fee has not been fastened / recovered from the
students by factoring it in the tuition fee, any amount of GST on
affiliation fee already paid by the petitioner shall be refunded
within four months, failing which the same shall also attract
interest @ 7% per annum from the date of payment till refund.
(YOGENDRA KUMAR PUROHIT),J (ARUN MONGA),J
Anshul/-
Appendix “A”
S.
Writ Petition
Case Details Relief Claimed
No.
Number
1.
2906/2022 T RIBAL AREA PRIVATE
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE WELFARE SOCIETY
COMMUNICATION/ LETTER/ NOTICE
V/S
DATED 30/12/2021.
UNION OF INDIA & Ors.
2.
7559/2022 SWA POSHIT SHIKSHAK
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
PRASHIKSHAN
COMMUNICATION/ LETTER/ NOTICE
MAHAVIDYALAYA SAMITI
DATED 30/12/2021.
V/S
MOHANLAL SUKHADIA
UNIVERSITY, UDAIPUR & Ors.
3.
8814/2022 NIJI COLLEGE SAMITI
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
JODHPUR SAMBHAG
COMMUNICATION/ LETTER/ NOTICE
V/S
DATED 30/12/2021.
JAI NARAIN VYAS
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(43 of 45)
[2026:RJ-JD:9475-DB] [CW-9556/2024]
UNIVERSITY, JODHPUR &
Ors.
4.
9514/2022 NIJI COLLEGE SHIKSHAN
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN WELFARE
COMMUNICATION/ LETTER/ NOTICE
SOCIETY
DATED 30/12/2021.
THE JAI NARAIN VYAS
UNIVERSITY, JODHPUR & Ors.
5.
19516/2022 SWAIM SEVI SHIKSHNIK
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN SANRAKSHAN
COMMUNICATION/ LETTER/ NOTICE
SANSTHAN
DATED 30/12/2021.
STATE OF RAJASTHAN & Ors.
6.
6732/2023 AKHIL
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
BHARTIYA NIJI SANSTHAN
COMMUNICATION/ LETTER/ NOTICE
FEDERATION
DATED 30/12/2021.
DR. SARWAPALLI
RADHAKRISHAN AYURVED
UNIVERSITY & Ors.
7.
6867/2023 CHOUDHARY PARMARAM
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
GODARA AGRICULTURE
COMMUNICATION/ LETTER/ NOTICE
COLLEGE
DATED 30/12/2021.
UNION OF INDIA & Ors.
8.
7284/2023 NIJI COLLEGE SHIKSHAN
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN WELFARE
COMMUNICATION/ LETTER/ NOTICE
SOCIETY
DATED 30/12/2021.
THE JAI NARAIN VYAS
UNIVERSITY, JODHPUR & Ors.
9.
7701/2023 RAJASTHAN ENGINEERING
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGES SOCIETY
COMMUNICATION/ LETTER/ NOTICE
RAJASTHAN TECHNICAL
DATED 30/12/2021.
UNIVERSITY, KOTA & Ors.
10.
7702/2023 AKHIL BHARTIYA NIJI
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN FEDERATION
COMMUNICATION/ LETTER/ NOTICE
RAJASTHAN UNIVERSITY OF
DATED 30/12/2021.
VETERINARY AND ANIMAL
SCIENCES, BIKANER & Ors.
11.
8494/2023 RAJASTHAN PRADESH NIJI
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE SANGH
COMMUNICATION/ LETTER/ NOTICE
THE MAHARSHI DAYANAND
DATED 30/12/2021.
SARASWATI UNIVERSITY,
AJMER, RAJASTHAN & Ors.
12.
8830/2023 SWAPOSHIT SHIKSHAK
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
PRASHIKSHAN
COMMUNICATION/ LETTER/ NOTICE
MAHAVIDYALAY SAMITI
DATED 30/12/2021.
MOHANLAL SUKHADIA
UNIVERSITY & Ors.
13.
8839/2023 SORABH AGRICULTURE
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE
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COMMUNICATION/ LETTER/ NOTICE
THE AGRICULTURE
DATED 30/12/2021.
UNIVERSITY & Ors.
14.
8900/2023 SHOURABH COLLEGE OF
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
VETERINARY SCIENCE
COMMUNICATION/ LETTER/ NOTICE
THE RAJASTHAN UNIVERSITY
DATED 30/12/2021.
OF VETERINARY AND ANIMAL
SCIENCES & Ors.
15.
8999/2023 RAJASTHAN COLLEGE OF
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
ANIMAL HUSBANDRY
COMMUNICATION/ LETTER/ NOTICE
STATE OF RAJASTHAN & Ors.
DATED 30/12/2021.
16.
10797/2023 NIJI COLLEGE SHIKSHAN
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN WELFARE
COMMUNICATION/ LETTER/ NOTICE
SOCIETY
DATED 30/12/2021.
THE JAI NARAIN VYAS
UNIVERSITY, JODHPUR &
Ors.
17.
3604/2024 SWAIM SEVI SHIKSHNIK
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
SANSTHAN SANRAKSHAN
COMMUNICATION/ LETTER/ NOTICE
SANSTHA
DATED 30/12/2021.
THE STATE OF RAJASTHAN &
Ors.
18.
8877/2024 SHRI SHYAM MAHILA
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
MAHAVIDYALAYA
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
19.
8879/2024 M.D.M. HIGHER EDUCATION
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
20.
8881/2024 M.D. COLLEGE OF
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
EDUCATION
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
21.
8883/2024 BABY HAPPY MODERN P.G.
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
22.
8885/2024 MURLI SINGH YADAV
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
MEMORIAL PRASHIKSHAN
COMMUNICATION/ LETTER/ NOTICE
SANSTHAN
DATED 30/12/2021.
THE MAHARAJA GANGA
SINGH UNIVERSITY & Ors.
23.
8887/2024 RYAN COLLEGE FOR HIGHER
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
EDUCATION
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
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[2026:RJ-JD:9475-DB] [CW-9556/2024]
SINGH UNIVERSITY & Ors.
24.
8893/2024 M.D.M. CO. EDUCATION B.ED.
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
COLLEGE
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
25.
8907/2024 BALAJI COLLEGE OF
QUASHING OF LEVY OF SERVICE TAX
BY THE UNIVERSITY PURSUANT TO
EDUCATION
COMMUNICATION/ LETTER/ NOTICE
THE MAHARAJA GANGA
DATED 30/12/2021.
SINGH UNIVERSITY & Ors.
26.
18070/2024 ALL INDIA ASSOCIATION OF
QUASHING OF LEVY OF SERVICE TAX
UNAIDED PRIVATE
BY THE UNIVERSITY PURSUANT TO
INSTITUTIONS (AIAUPI)
COMMUNICATION/ LETTER/ NOTICE
THE RAJASTHAN UNIVERSITY
DATED 06.01.2024, 07.12.2023 AND
OF HEALTH SCIENCES &
04.11.2023
Ors.
27.
11791/2025 MAHARAJA GANGA SINGH
QUASHING OF SHOW CAUSE NOTICE
UNIVERSITY
DATED 12.03.24 ISSUED BY
UNION OF INDIA & Ors.
COMMISSIONER, CGST & C. EXCISE,
JODHPUR AND NOTICE-IN-ORIGINAL
DATED 28.01.2025 PASSED BY
COMMISSIONER, CGST & C. EXICSE,
JODHPUR.
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