NSDC Approval on Private Courses Does Not Grant GST Exemption
Maharashtra AAR ruled that private courses approved by NSDC are not exempt from GST unless delivered under specific government schemes.
- Ruling
- NO.GST-ARA-37/2017-18/B-44 dated 05.06.2018
- Dated
- 05 Jun 2018
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- IMS Proschool asked if NSDC-approved courses qualify for GST exemption.
- AAR held that course approval or certification by NSDC is not exempt.
- Exemption under Notification 12/2017 applies only to government-implemented NSDC schemes.
- Courses sold commercially to individuals or corporates remain subject to standard GST.
In short
The company, an approved training partner of the National Skill Development Corporation (NSDC), offered various vocational courses. Some courses had full NSDC approval, some had interim approval, and others were delivered through sub-contractors across India. The company argued that because NSDC approved its courses, these services were exempt from GST under Entry 69 of Notification No. 12/2017-Central Tax (Rate).
What has changed
How it worked before
Many training institutes assumed that becoming an NSDC partner or getting NSDC affiliation for their private training courses was enough to claim a total GST exemption on student fees.
What has changed
The Authority for Advance Ruling (AAR) decided that simple affiliation or course approval from NSDC does not qualify for GST exemption. The tax exemption under Entry 69 of Notification No. 12/2017-Central Tax (Rate) is strictly for specific government skill development schemes implemented directly by NSDC, such as PMKVY. As a result, commercial training institutes must charge full GST on courses that are merely approved by NSDC rather than run under an official government scheme.
Who this affects
Private coaching centres, vocational training institutes, and skill development partners affiliated with NSDC that charge fees directly from students or corporate clients.
An example
A private IT institute becomes an NSDC training partner and creates a data analytics diploma course. They get the course syllabus accredited by NSDC and charge students fifty thousand rupees per course. They ask whether they can stop collecting GST on these student fees due to NSDC accreditation. This ruling suggests that since the institute is selling its own commercial course rather than executing an official government scheme like PMKVY, full GST must be charged.
What you should do
Check whether your training courses are executed under an official government scheme implemented by NSDC or are privately offered commercial courses. Remember that an advance ruling binds only the business that applied for it and its local tax authority. If you have a similar setup, consult a tax advisor or apply for your own advance ruling before stopping GST collection on course fees.
If you do nothing
If you assume your NSDC-affiliated courses are exempt without running an official government skill scheme, tax officers may demand uncollected GST later. You could be liable to pay full back-dated GST out of your own pocket along with heavy interest and penalties. Misinterpreting course approval as a statutory tax exemption can lead to severe financial penalties during a tax audit.
The terms explained
- National Skill Development Corporation
- A public-private organization set up by the Indian government to promote skill development and approve vocational training standards.
- Entry 69 of Notification No. 12/2017
- A specific GST rule that exempts skill training services from tax when provided under approved government-backed skill schemes.
- input tax credit
- The GST a business pays on its purchases, which it can deduct from the GST it collects on sales.
The ruling in detail
Authority for Advance Ruling
IMS PROSCHOOL PVT LTD.
NO.GST-ARA-37/2017-18/B-44 dated 05.06.2018 · Maharashtra
Questions before the authority
- Whether educational courses offered by the Applicant which have been approved by National Skill Development Corporation (hereinafter referred to as "NSDC") would be construed as in relation to National Skill Development Programme implemented by NSDC?
- The Applicant offers certain educational courses for which qualification standards/framework i.e. QP/ NOS has not been defined by NSDC and will be approved by NSDC as and when the relevant QP/ NOS would be defined by NSDC. In the interim period, NSDC has given exceptional approval on such courses. Till the time QP/ NOS are defined for such educational courses and are eventually approved by NSDC, whether such courses will be treated as in relation to National Skill Development Programme implemented by NSDC?
- In certain situations, NSDC approved educational courses are subsequently, upgraded by the Applicant within pre-defined QP/ NOS framework, by way of adding more topics/ content /modules. However, such modified version of NSDC approved educational courses have not been approved by NSDC yet. Whether such modified version will be treated as in relation to National Skill Development Programme implemented by NSDC?
- If the answer to Q.1, Q.2 and Q.3 are Yes, then whether the benefit of GST exemption as per Notification No. 12/2017- Central Tax (Rate), dated the 28th June 2017 would be available to the Applicant?
- If answer to Q.4 is Yes, whether benefit of GST exemption as per Notification No. 12/2017- Central Tax (Rate), dated the 28th June 2017 would be still available if such educational courses are offered to corporates and business institutions?
- Whether the NSDC approved educational courses which are actually imparted by the business partners of the Applicant, on behalf of the Applicant as sub-contractor of Applicant, at various centres located across the country, will be considered as offered by the Applicant?
- If answer to Q.6 is Yes, whether benefit of GST exemption as per Notification No. 12/2017- Central Tax (Rate), dated the 28th June 2017 would be available to the Applicant?
Facts
The applicant is an approved training partner of National Skill Development Corporation (NSDC) providing educational training and skilling courses across India to individuals, corporates, and government bodies. Some courses offered are approved by NSDC, some carry interim or exceptional approval pending Qualification Packs/National Occupational Standards (QP/NOS) definition, and some are modified or upgraded versions. The applicant also engages business partners as sub-contractors to deliver these courses at various centres across the country.
Ruling
| Question | What the authority ruled |
|---|---|
| NSDC-approved educational courses as relation to NSDC programme | Answered in the negative. Courses designed by applicant and approved by NSDC do not constitute a programme implemented by NSDC. |
| Courses with interim/exceptional approval pending QP/NOS definition | Answered in the negative. Not treated as in relation to National Skill Development Programme implemented by NSDC. |
| Upgraded/modified versions of NSDC-approved courses not yet re-approved | Answered in the negative. Not treated as in relation to National Skill Development Programme implemented by NSDC. |
| GST exemption under Notification No. 12/2017-Central Tax (Rate) | No In view of answers to Q.No. 1, 2 and 3. |
| Exemption availability when courses are offered to corporates/business institutions | No In view of answers to Questions above. |
| Courses imparted through business partners considered as offered by Applicant | Not relevant and not being answered In view of the answers to questions above. |
| Exemption availability for courses imparted through business partners | No In view of answers to Questions above. |
The Authority held that the educational courses offered by the applicant are not in relation to the **National Skill Development Programme implemented by NSDC**. The applicant merely receives course approval and certification from NSDC rather than delivering a scheme implemented directly by NSDC. Consequently, GST exemption under Entry 69 of Notification No. 12/2017-Central Tax (Rate) is **not available** to the applicant.
Reasoning
The Authority examined Entry 69 of Notification No. 12/2017-Central Tax (Rate), which exempts training services provided by an approved training partner in relation to a National Skill Development Programme implemented by NSDC or specific government skill schemes. It observed that the applicant creates its own curriculum and seeks approval and certification from NSDC, making the applicant a recipient of certification services from NSDC rather than an executing partner for a scheme implemented by NSDC. Government skill development programmes implemented by NSDC refer to specific government-funded initiatives such as PMKVY, SANKALP, UDAAN, or STAR schemes. In the absence of an explicit government-implemented programme under which the training is executed, mere **approval or accreditation of private courses by NSDC** does not qualify for tax exemption.
Provisions relied on
- Section 97 of CGST Act, 2017
- Section 98 of CGST Act, 2017
- Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 (Entry 69, HSN 9992)
For the practitioner
This ruling establishes that **mere accreditation or approval of training courses by NSDC** is insufficient to claim GST exemption under Entry 69 of Notification No. 12/2017-Central Tax (Rate). To qualify for exemption, the training provider must deliver services under a specific **government skill scheme implemented directly by NSDC** (such as PMKVY). Commercially run courses with general NSDC affiliation or certification remain fully taxable.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/mah_aar_37_2017-18_b-44_05.06.2018_imsppl.pdf
Legibility of the scan, as read: high.
Prepared 18-10-2026.
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