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GST on supply of coaching services along with supply of goods/printed material/test papers, uniform, bags

Authority for Advance Ruling —– Coaching Services -- The applicant intended to provide coaching services to its enrolled students under its supervision through Network partner. The applicant sought an advance ruling submitting that they supply services of coaching to students which also includes along with coaching, supply of goods/printed material/test papers, uniform, bags and other goods to students. Such supplies are not charged separately but a consolidated amount is charged, the major component of which is imparting of coaching. In such circumstances, whether such supply shall be considered, a supply goods or a supply of services; if the answer is supply of service, whether such supply shall be considered as composite supply, If yes, what shall be the principal supply; Applicant provides coaching service under a business model through Network Partners as per sample agreement attached, containing obligations of Applicant and Network partners. Accordingly, the network partner provides the services to the students on behalf of Applicant. In such a case, who shall be considered as supplier of service and recipient of service under the agreement; what shall be the value of service provided by Applicant to students and by network partner to Applicant; whether both, Applicant and network partner can avail eligible ITC for their respective supplies. Held that:- The Hon’ble Authority for Advance Ruling held the Supply by the applicant will be considered Supply of Service. Such supply shall be considered as Composite supply, and Coaching service shall be principal supply. Applicant will be service provider to the students and Network partner will be service provider to the applicant. Total consolidated amount charged for which Tax invoice generated by the applicant will be the value of service supply by the applicant. Applicant can avail eligible ITC as per provisions of Act, 2017.
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