Academic Coaching for Students Taxable at 18% GST: AAR Clarifies Scope of ‘Educational Institution’ under Notification [Read Order]

In a recent ruling, the Gujarat Authority for Advance Ruling (AAR) has held that academic coaching services provided by Friends Classes to students of Standards 5 to 12 under the GSEB/CBSE curriculum are not exempt under Entry 66 of Notification No. 12/2017‑CTR. The authority concluded that such services fall under SAC 999293, “Commercial Training and Coaching Services,” and attract GST at 18%.

The applicant, Sanjaykumar Ishwerlal Sadadiwala, proprietor of Friends Classes, sought an advance ruling on whether supplementary academic coaching for school students could be treated as “education services” provided by an educational institution. The institute, established in 1984, offers tuition to students in Standards 5 to 12 to help improve their academic performance.

Appearing for the applicant, CA Bhavesh D. Saraiya argued that the classes impart fundamental education and should be exempt, emphasizing that education up to Class 12 is a constitutional right and that taxation would make quality learning less accessible to middle‑ and low‑income groups.

After examining the submissions, the AAR observed that the exemption under Entry 66 applies only to services provided by an “educational institution” as defined in para 2(y) of Notification No. 12/2017‑CTR, namely, institutions offering pre‑school education, education up to higher secondary school, or education forming part of a recognized curriculum or approved vocational course.

The bench comprising Members Vishal Malani (CGST) and Sushma Vora (SGST) noted that Friends Classes merely provides supplementary education, additional coaching beyond the regular school curriculum, and therefore does not qualify as an “educational institution.” Consequently, the exemption under Entry 66 was held inapplicable.

Referring to Notification No. 11/2017‑CTR, the authority classified the applicant’s services as Education Services, specifically Entry 599 (SAC 999293) for “Commercial Training and Coaching Services.”

Accordingly, the AAR ruled that the coaching services rendered by Friends Classes to students of Standards 5 to 12 are taxable at 18% GST, rejecting the claim for exemption under Notification No. 12/2017‑CTR.

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