Rajasthan Technical University vs Union Of India (2026:Rj-Jd:9475-Db)
2026 Latest Caselaw 2920 Raj

Rajasthan High Court - Jodhpur

Rajasthan Technical University vs Union Of India (2026:Rj-Jd:9475-Db) on 23 February, 2026

Author: Yogendra Kumar Purohit

Bench: Yogendra Kumar Purohit

[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. Chapter, Section, Description of Services Rate Conditio No. Heading, Group (percent) n or Service Code(Tariff) (1) (2) (3) (4) (5) XXXX XXXX XXXX XXXX XXXX 66 Heading 9992 of Service Provided Heading 9963 (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

Authority.1 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

Abdul Azee Sahib and Ors.2).

(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

Services Tax.3and Bengaluru North University vs. Joint

Commissioner of Central Tax, GST Commissionerate.4, have

consistently adopted a broad interpretation of "education,"

drawing ratio inter alia from Sole Trustee, Lok Shikshana Trust

v. CIT.5and T.M.A. Pai Foundation v. State of Karnataka.6 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

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

Melting & Wire Industries.7and Sandur Micro Circuits Ltd. v.

CCE.8

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 Goods and Services Tax.9

b. Bengaluru North University vs. Joint Commissioner of Central Tax, GST Commissionerate.10

c. Principal Additional Director General, DGGSTI vs. Rajiv Gandhi University of Health Sciences. 11

d. Principal Additional Director General, DGGSTI vs. Rajiv Gandhi University of Health Sciences. 12

e. M/s Doypack Systems Pvt. Ltd. Vs. Union of India &Ors.,13

f. Renusagar Power Co. Ltd. Vs. General Electric Company &Anr.,14

g. Coca Cola India (P.) Ltd. Vs. Commissioner of Central Excise, Pune III.15

h. Commissioner of Central Excise & Customs vs. Parth Poly Wooven (P.) Ltd16

i. State Wakf Board, Madras Vs Abdul Azee Sahib and Ors.17

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

11 (2025) 32 Centex 526 (Kar.)

13 (1988) 2 SCC 29 14 (1984) 4 SCC 679 15 Central Excise Appeal No.118/2007 Bombay 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

Dilip Kumar and Company and Ors.18

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ii Krishi Upaj Mandi Samiti, New Mandi Yard, Alwar

Vs. Commissioner of Central Excise and Service Tax,

Alwar.19

iii Care College of Nursing and Ors. Vs. Kaloji

Narayana Rao University of Health Sciences and Ors. 20

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

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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

judgment of Delhi High Court in NBEMS Vs. Union of India 21. 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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(i) Madurai Kamaraj University v. Joint Commissioner,22

"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

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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

(GST Intelligence).23

"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

and Services Tax.24

"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

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

relied upon Advance Ruling in Bharathiar University 25, 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       TRIBAL      AREA       PRIVATE QUASHING OF LEVY OF SERVICE TAX
                        COLLEGE WELFARE SOCIETY BY            THE   UNIVERSITY   PURSUANT   TO

                        V/S                              COMMUNICATION/      LETTER/   NOTICE

                        UNION OF INDIA & Ors.            DATED 30/12/2021.

2.      7559/2022       SWA      POSHIT     SHIKSHAK QUASHING OF LEVY OF SERVICE TAX
                        PRASHIKSHAN                      BY   THE   UNIVERSITY   PURSUANT   TO

                        MAHAVIDYALAYA           SAMITI COMMUNICATION/        LETTER/   NOTICE

                        V/S                              DATED 30/12/2021.

                        MOHANLAL            SUKHADIA
                        UNIVERSITY, UDAIPUR & Ors.

3.      8814/2022       NIJI     COLLEGE        SAMITI QUASHING OF LEVY OF SERVICE TAX
                        JODHPUR              SAMBHAG BY       THE   UNIVERSITY   PURSUANT   TO

                        V/S                              COMMUNICATION/      LETTER/   NOTICE

                        JAI       NARAIN          VYAS DATED 30/12/2021.


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                   UNIVERSITY,       JODHPUR       &
                   Ors.

4.    9514/2022    NIJI    COLLEGE         SHIKSHAN QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN                 WELFARE BY      THE   UNIVERSITY   PURSUANT   TO

                   SOCIETY                             COMMUNICATION/      LETTER/   NOTICE

                   THE      JAI     NARAIN      VYAS DATED 30/12/2021.
                   UNIVERSITY, JODHPUR & Ors.

5.    19516/2022   SWAIM          SEVI     SHIKSHNIK QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN              SANRAKSHAN BY      THE   UNIVERSITY   PURSUANT   TO

                   SANSTHAN                            COMMUNICATION/      LETTER/   NOTICE

                   STATE OF RAJASTHAN & Ors.           DATED 30/12/2021.

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
                   GODARA                AGRICULTURE BY THE UNIVERSITY PURSUANT TO
                   COLLEGE                             COMMUNICATION/      LETTER/   NOTICE

                   UNION OF INDIA & Ors.               DATED 30/12/2021.

8.    7284/2023    NIJI    COLLEGE         SHIKSHAN QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN                 WELFARE BY THE UNIVERSITY PURSUANT TO
                   SOCIETY                             COMMUNICATION/      LETTER/   NOTICE

                   THE      JAI     NARAIN      VYAS DATED 30/12/2021.
                   UNIVERSITY, JODHPUR & Ors.

9.    7701/2023    RAJASTHAN             ENGINEERING QUASHING OF LEVY OF SERVICE TAX
                   COLLEGES                  SOCIETY BY THE UNIVERSITY PURSUANT TO
                   RAJASTHAN       TECHNICAL COMMUNICATION/ LETTER/                  NOTICE

                   UNIVERSITY, KOTA & Ors.   DATED 30/12/2021.

10.   7702/2023    AKHIL          BHARTIYA       NIJI QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN               FEDERATION BY THE UNIVERSITY PURSUANT TO
                   RAJASTHAN UNIVERSITY OF COMMUNICATION/ LETTER/                    NOTICE

                   VETERINARY AND ANIMAL DATED 30/12/2021.
                   SCIENCES, BIKANER & Ors.

11.   8494/2023    RAJASTHAN         PRADESH    NIJI QUASHING OF LEVY OF SERVICE TAX
                   COLLEGE                    SANGH BY THE UNIVERSITY PURSUANT TO
                   THE     MAHARSHI        DAYANAND COMMUNICATION/ LETTER/           NOTICE

                   SARASWATI              UNIVERSITY, DATED 30/12/2021.
                   AJMER, RAJASTHAN & Ors.

12.   8830/2023    SWAPOSHIT               SHIKSHAK QUASHING OF LEVY OF SERVICE TAX
                   PRASHIKSHAN                      BY THE UNIVERSITY PURSUANT TO

                   MAHAVIDYALAY               SAMITI COMMUNICATION/ LETTER/          NOTICE

                   MOHANLAL                SUKHADIA DATED 30/12/2021.
                   UNIVERSITY & Ors.

13.   8839/2023    SORABH                AGRICULTURE QUASHING OF LEVY OF SERVICE TAX
                   COLLEGE                           BY THE UNIVERSITY PURSUANT TO



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                   THE                  AGRICULTURE COMMUNICATION/        LETTER/   NOTICE

                   UNIVERSITY & Ors.                  DATED 30/12/2021.

14.   8900/2023    SHOURABH         COLLEGE      OF QUASHING OF LEVY OF SERVICE TAX
                   VETERINARY               SCIENCE BY     THE   UNIVERSITY   PURSUANT   TO

                   THE RAJASTHAN UNIVERSITY COMMUNICATION/                LETTER/   NOTICE

                   OF VETERINARY AND ANIMAL DATED 30/12/2021.
                   SCIENCES & Ors.

15.   8999/2023    RAJASTHAN        COLLEGE      OF QUASHING OF LEVY OF SERVICE TAX
                   ANIMAL                HUSBANDRY BY      THE   UNIVERSITY   PURSUANT   TO

                   STATE OF RAJASTHAN & Ors.          COMMUNICATION/      LETTER/   NOTICE
                                                      DATED 30/12/2021.
16.   10797/2023   NIJI    COLLEGE        SHIKSHAN QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN                 WELFARE BY     THE   UNIVERSITY   PURSUANT   TO

                   SOCIETY                            COMMUNICATION/      LETTER/   NOTICE

                   THE     JAI     NARAIN      VYAS DATED 30/12/2021.
                   UNIVERSITY,      JODHPUR       &
                   Ors.

17.   3604/2024    SWAIM         SEVI     SHIKSHNIK QUASHING OF LEVY OF SERVICE TAX
                   SANSTHAN             SANRAKSHAN BY      THE   UNIVERSITY   PURSUANT   TO

                   SANSTHA                            COMMUNICATION/      LETTER/   NOTICE

                   THE STATE OF RAJASTHAN & DATED 30/12/2021.
                   Ors.

18.   8877/2024    SHRI       SHYAM          MAHILA QUASHING OF LEVY OF SERVICE TAX
                   MAHAVIDYALAYA                      BY   THE   UNIVERSITY   PURSUANT   TO

                   THE      MAHARAJA         GANGA COMMUNICATION/         LETTER/   NOTICE

                   SINGH UNIVERSITY & Ors.            DATED 30/12/2021.

19.   8879/2024    M.D.M. HIGHER EDUCATION QUASHING OF LEVY OF SERVICE TAX
                   COLLEGE                            BY   THE   UNIVERSITY   PURSUANT   TO

                   THE      MAHARAJA         GANGA COMMUNICATION/         LETTER/   NOTICE

                   SINGH UNIVERSITY & Ors.            DATED 30/12/2021.

20.   8881/2024    M.D.          COLLEGE         OF QUASHING OF LEVY OF SERVICE TAX
                   EDUCATION                          BY   THE   UNIVERSITY   PURSUANT   TO

                   THE      MAHARAJA         GANGA COMMUNICATION/         LETTER/   NOTICE

                   SINGH UNIVERSITY & Ors.            DATED 30/12/2021.


21.   8883/2024    BABY HAPPY MODERN P.G. QUASHING OF LEVY OF SERVICE TAX
                   COLLEGE                            BY   THE   UNIVERSITY   PURSUANT   TO

                   THE      MAHARAJA         GANGA COMMUNICATION/         LETTER/   NOTICE

                   SINGH UNIVERSITY & Ors.            DATED 30/12/2021.


22.   8885/2024    MURLI         SINGH        YADAV QUASHING OF LEVY OF SERVICE TAX
                   MEMORIAL             PRASHIKSHAN BY     THE   UNIVERSITY   PURSUANT   TO

                   SANSTHAN                           COMMUNICATION/      LETTER/   NOTICE

                   THE      MAHARAJA         GANGA DATED 30/12/2021.
                   SINGH UNIVERSITY & Ors.

23.   8887/2024    RYAN COLLEGE FOR HIGHER QUASHING OF LEVY OF SERVICE TAX
                   EDUCATION                          BY   THE   UNIVERSITY   PURSUANT   TO

                   THE      MAHARAJA         GANGA COMMUNICATION/         LETTER/   NOTICE
                                                      DATED 30/12/2021.


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                                                      SINGH UNIVERSITY & Ors.

                                   24.   8893/2024    M.D.M. CO. EDUCATION B.ED. QUASHING OF LEVY OF SERVICE TAX
                                                      COLLEGE                    BY THE UNIVERSITY PURSUANT TO

                                                      THE      MAHARAJA  GANGA COMMUNICATION/ LETTER/                NOTICE

                                                      SINGH UNIVERSITY & Ors.  DATED 30/12/2021.


                                   25.   8907/2024    BALAJI       COLLEGE         OF QUASHING OF LEVY OF SERVICE TAX
                                                      EDUCATION                       BY THE UNIVERSITY PURSUANT TO

                                                      THE      MAHARAJA      GANGA COMMUNICATION/ LETTER/            NOTICE

                                                      SINGH UNIVERSITY      & Ors. DATED 30/12/2021.

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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