Affiliation Fees Collected by University from 2012- 2016 Exempted from Service Tax: CESTAT [Read Order]
The demand raised by revenue over service tax on affiliation fees collected by the university during July 2012 to December 2016 was set aside by the tribunal.
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The Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ), New Delhi, has held that affiliation fees collected by a university from affiliated colleges from 2012 to 2016 are not liable to service tax. The matter pertained to M/s. Rani Durgavati Vishwavidyalaya, a central university established under the Madhya Pradesh Vishwavidyalaya Adhiniyam, 1973. The appeal was filed by...
The Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ), New Delhi, has held that affiliation fees collected by a university from affiliated colleges from 2012 to 2016 are not liable to service tax.
The matter pertained to M/s. Rani Durgavati Vishwavidyalaya, a central university established under the Madhya Pradesh Vishwavidyalaya Adhiniyam, 1973. The appeal was filed by the Principal Commissioner of CGST & Central Excise.
The Revenue had raised a demand of over ₹1.58 crore as service tax on affiliation fees and rental income collected by the university during July 2012 to December 2016. However, the Commissioner (Appeals) had earlier set aside this demand, recognizing the services as part of core educational functions.
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On appeal by the Revenue, the CESTAT reaffirmed the exemption, stating that affiliation activities are integral to the delivery of higher education, thus falling under the negative list of services or within the scope of exempted educational services under Notification No. 25/2012-ST.
The bench of Binu Tamta (judicial member) and Hemambika R Priya (Technical member) cited precedents including the Karnataka High Court’s ruling in Rajiv Gandhi University of Health Sciences, upheld by the Supreme Court, which clarified that affiliation services are directly linked to education and therefore not taxable.
The tribunal, dismissing the Revenue’s appeal, upheld the university’s exemption from service tax for the financial year in dispute.
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To Read the full text of the Order CLICK HERE
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