Advance Ruling— In the instant case, the applicant is a private limited company in the state of Rajasthan, is engaged in imparting commercial coaching service in the field of science stream to the students inspiring to clear medical and engineering entrance examinations like NEET, JEE etc. and provides the best facilities to the students in terms of video lectures, Digital learning, online mock tests etc.

That the applicant intends to provide hostel facility not only to the students who are enrolled with applicant for coaching service but also to the students of nearby schools/educational institutions.

QUESTIONS ON WHICH THE ADVANCE RULING IS SOUGHT

A. Whether the activity of providing the hostel facility on the rent to various students by applicant is exempt (where hostel fees charged per student per day is much less than Rs.1000/-)?

B. If it is exempt, under which entry of Notification No.12/2017-Central Tax (Rate) (as amended time to time) dated 28.06.2017, it is covered?

Held that— This authority is not in a position to decide whether the said supply is mixed or composite supply. Thus, it is of the view that in absence of supporting documentary evidence in support of services to be provided by the applicant, how it can classify in HSN provided in the CGST Act, 2017 and thus there is no question to discuss the exemption under Sr. No. 14 of the of the Notification No. 12/2017-CT(Rate) dated 28.06.2017. Thus, with the limited material fact submitted by the applicant, with no Brochure of Hostel facilities, Break-up of fees in respect of facilities/services to be provided, License from the Local Authority and Rent Agreement etc.' we find it prudent to refrain from pronouncing a Ruling. Therefore, no ruling is extended on the clarifications sought by applicant.