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Advance rulings (AAR) Andhra Pradesh

GST on Coaching Centers: Are CA and CMA Classes Exempt?

Private coaching centers for professional exams like CA and CMA are not educational institutions and must charge GST on their services.

Ruling
AAR No.08 /AP/GST/2020 dated:05.03.2020
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

  1. Coaching centers are not 'educational institutions' under GST law.
  2. Services provided by coaching centers are taxable, not exempt.
  3. Food and accommodation provided by coaching centers are also taxable.

In short

The company asked the Authority for Advance Ruling (AAR) if their coaching services for CA and CMA students were exempt from Goods and Services Tax (GST). They also asked if the food and hostel facilities they provide to these students should be tax-free. The authority decided that because the coaching center is not an officially recognized educational institution, all these services are subject to GST.

What has changed

How it worked before

Many private coaching centers assumed that because they teach a curriculum prescribed by statutory bodies like the ICAI, their services should be exempt from GST just like schools and colleges.

What has changed

The ruling clarifies that coaching centers are not 'educational institutions' because they are not formally accredited or authorized by the statutory bodies to grant degrees or certificates. This means coaching fees, hostel charges, and catering fees collected by such centers are fully taxable. In practice, coaching centers must now collect and pay GST on all these services.

Who this affects

Private coaching centers, tuition providers, and training institutes preparing students for professional exams like CA, CMA, or competitive entrance tests.

An example

Imagine a private coaching center in another state that prepares students for medical entrance exams. They might wonder if they can stop charging GST based on this ruling. This ruling suggests that their tax officer will likely view them the same way, meaning they must continue to pay GST because they are not a recognized educational institution.

What you should do

If you run a coaching center, you should consult with your tax advisor to ensure you are correctly charging and paying GST. Remember that an Advance Ruling only binds the specific business that asked for it and their local tax office; it is not a general law that applies to everyone automatically.

If you do nothing

If you assume this ruling does not apply to you and stop paying GST, you risk a tax audit. If the authorities decide you owe tax, you will have to pay the unpaid GST plus interest and potential penalties. This can create a significant financial burden for your business.

The terms explained

Educational institution
An entity that provides education as part of a curriculum for a qualification recognized by law, such as a school or university.
Statutory body
An organization established by an act of Parliament or state legislature to regulate a specific profession or field, such as the Institute of Chartered Accountants of India.
Advance ruling
A formal decision from tax authorities on how GST law applies to a specific business situation.

The ruling in detail

Authority for Advance Ruling

M/s. Master Minds

AAR No.08 /AP/GST/2020 dated:05.03.2020 · Andhra Pradesh

Questions before the authority

  • Whether the services of supply of service of education as per the curriculum prescribed by the statutory authorities/ government to the students of the applicant for obtaining qualifications/ certificates of CA-Foundation, CA-Inter, CA-Final, CMA (ICWA)-Foundation, CMA-Inter, CMA-Final and Intermediate duly recognized by the respective statutory authorities/ government are exempted under Notification No.12/2017-CT (Rate) dt.28.06.2017 (entry no.66(a)), as amended?
  • Whether the charges collected for providing accommodation to the students undergoing the above courses are exempted from GST as provided under Notification No.12/2017-CT (Rate) dt.28.06.2017 (entry no.14), as amended read with Circular No.32/06/2018-GST dt.12.2.2018 since the amount charged from the students by the hostel run by the applicant is less than Rs.1000/- per day?
  • Whether the charges collected by the applicant for catering service by supplying food to the students undergoing the above courses are exempted from GST as provided under Notification No.12/2017-CT (Rate) dt.28.06.2017 (entry no.66(a)), as amended?

Facts

The applicant is a proprietary firm providing coaching services to students for Chartered Accountancy (CA) and Cost Management Accountancy (CMA) courses, as well as Intermediate education. The applicant sought a ruling on whether these coaching services, along with the provision of food and accommodation to students, qualify for GST exemption as an educational institution. The applicant argued that their coaching is provided as part of a curriculum for obtaining qualifications recognized by law.

Ruling

QuestionWhat the authority ruled
Exemption for coaching servicesNot eligible
Applicant is not an educational institution
Exemption for accommodation chargesNot eligible
Applicant is not an educational institution
Exemption for catering servicesNot eligible
Applicant is not an educational institution

The Authority ruled that the applicant does not qualify as an educational institution under the relevant notifications. Consequently, the coaching services, as well as the supply of food and accommodation, are not eligible for the claimed GST exemptions. The applicant is required to pay GST on these services.

Reasoning

The Authority reasoned that the applicant is not an educational institution as defined in Notification No.12/2017-Central Tax (Rate) because they are not accredited, affiliated, or authorized by the statutory bodies (ICAI/ICWAI) to impart the curriculum. The coaching provided is merely a **facilitation or improvisation** for students to prepare for exams and does not lead to the grant of a certificate or qualification by the applicant itself. Furthermore, the exemption for food and accommodation is only available when provided by an educational institution to its students, which the applicant is not.

Provisions relied on

  • Notification No.12/2017-Central Tax (Rate) dated 28.06.2017
  • Notification No.2/2018-Central Tax (Rate) dated 25.01.2018
  • Circular No.85/04/2019-GST dated 01.01.2019

For the practitioner

This ruling clarifies that private coaching centers preparing students for professional exams like CA and CMA do not qualify as **educational institutions** for the purpose of GST exemptions. Practitioners should note that the lack of formal accreditation or affiliation with the statutory body is a **decisive factor** in denying the exemption. It confirms that coaching services are taxable even if they relate to a curriculum prescribed by a statutory body.

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/aar_no.8-2020_mater_mind.pdf

Legibility of the scan, as read: high.

Prepared 20-10-2026.

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Does this ruling mean I have to pay GST on my coaching fees?

Yes, if you are a private coaching center that is not an officially recognized educational institution, your services are taxable.

Is this ruling binding on my business?

No, an Advance Ruling is only legally binding on the business that requested it and their specific tax officer. However, it shows how the authorities interpret the law, which is a strong indicator of how they might treat your business.

What if my local tax officer disagrees with this ruling?

Tax officers generally follow the guidance provided by Advance Rulings. If you are unsure about your tax status, you should seek your own professional advice or apply for your own ruling.

Are hostel fees for students always taxable?

Hostel fees are only exempt if provided by a recognized educational institution to its students. Since private coaching centers do not qualify as such, their hostel fees are taxable.