Limitation— The present appeal has been filed against the Advance Ruling order.

The Appellant is a Professor of Law at the National Law School of India University (NLSIU), Bangalore and engages in classroom teaching and training for students, the payments for which are made by the Government. 

The appellant had approached the Authority for Advance Ruling (AAR) seeking a ruling on the following questions:

a. "Whether the income earned from conducting Guest Lectures, amounts to or results in a taxable supply of service?

b. Whether the income earned from Research and Training Projects funded by Ministries of Government of India and State Government of Karnataka, amounts to results in a taxable supply of service to be taxed at Nil rate under Heading 9992?

c. Whether the income earned from Research and Training Projects funded by Ministries of Government of India and State Government of Karnataka, amounts to or results in a taxable supply to be taxed at IGST 18% under Heading 9983?”

The AAR gave the following ruling—

a. The income earned from conducting Guest Lectures, amounts to taxable supply of services as per Entry No (ii) of 21 of Notification No 11/2017-Central Tax (Rate) dated 28-06-2017.

b. In the absence of the details of the recipient of service, the service in question merits classification under SAC 9983 and attracts GST at the rate of 18%.

c. In the absence of the details of the recipient of service, the service in question merits classification under SAC 9983 and attracts GST at the rate of 18%.

The issue under appeal is whether the income earned by the Appellant from training and lectures given on Law and Legal awareness is taxable under GST.

The appeal has been filed after a delay of 65 days without taking into account condonation by AAAR. The Appellant has sought for condonation of delay by relying on the Supreme Court's order dated 10th January 2022.

Held that— This authority dismiss the appeal filed by the appellant on grounds of time limitation.