Levy of GST— The present application has been filed by the applicant, seeking an advance ruling in respect of the following questions.-

Whether the Applicant, in the capacity of being a NEEM facilitator, acts as a 'Pure Agent' while receiving reimbursement of stipend amounts from the various Trainer Institutes and remitting the same to the trainees?

If not, whether such stipend amount forms a part of the taxable value?

This Applicant, M/s Patle eduskills foundation, registered under the GST Laws is engaged in the business of Human Resource & Skill Development and is a facilitator under the National Employability Enhancement Mission ('NEEM Scheme') of the Govt, of India.

The Applicant is registered as a facilitator under the National Employability Enhancement Mission ('NEEM Scheme'). 

The first question does not pertain to any of the matters specified in clauses (a) to (g) of Section 97 (2) of the CGST Act, 2017 and therefore, this authority  refrain from answering question number 1 raised by the applicant.

With respect to second question, i.e. Payment of Stipend to the Trainees, as per the agreement, a monthly stipend shall be paid to the trainees by Trainer Institute by way of issuing a cheque in the name of the Applicant who is required to make such payment to the trainees. The sample agreement submitted mentions that, the Applicant is to act as a “Pure Agent” of the Trainer Institute.

The applicant has submitted that the stipend cost is recovered from the Trainer Institutes and the entire amount so recovered is paid to the trainees without any retention from the said amount of stipend, and therefore the stipend paid should be excluded from value of supply and hence the applicant will not be liable to discharge any GST on the stipend amount Received for payment to the trainees. 

Held that— it is held that the stipend paid by Entities/Training Institutes to the applicant to be further paid to the trainees in full does not attract GST and is not required to be added to the taxable value.