AAR Clarifies GST Exemption for NSDC Training Partners During Intervening Period

Case Details: In re: ASDM Institute Pvt. Ltd. (2026) 41 Centax 404 (A.A.R. - GST - Guj.)

Judiciary and Counsel Details

• • Ms Sushma Vora & Shri Vishal Malani, Member
  • Shri Rounak Mandowara, CA, for the Applicant.
  • Shri Patel Mit Dineshbhai, ACST(1), for the Respondent.

Facts of the Case

The applicant, an NSDC-approved training partner under the Skill India initiative, provided NSQF-aligned digital marketing courses to students. The courses were accredited by the National Skill Development Corporation (NSDC), student enrolments and training progress were monitored through the Skill India Portal, and certifications were issued under the NSDC framework. The applicant collected course fees directly from students under a market-led fee-based model without any direct government funding. Seeking clarity on GST implications, the applicant applied for an advance ruling on whether its training services qualified for exemption under Entry 69 of Notification No. 12/2017-CT(R), particularly in light of amendments made by Notification Nos. 08/2024-CT(R) and 06/2025-CT(R).

AAR Held

The Authority for Advance Ruling held that the applicant, being an NSDC-approved training partner providing NSQF-aligned courses under the NSDC skill development framework, was eligible for GST exemption under Entry 69 of Notification No. 12/2017-CT(R). However, during the period from 10.10.2024 to 15.01.2025, the exemption for NSDC-approved training partners stood withdrawn due to Notification No. 08/2024-CT(R) and was restored only with effect from 16.01.2025 by Notification No. 06/2025-CT(R). The Authority rejected the contention that the applicant could claim exemption during the intervening period as an NCVET-accredited training body. Nevertheless, in view of CBIC Circular No. 245/02/2025-GST, the intervening period was regularised on an “as is where is” basis. Accordingly, if GST had not been paid for that period, no liability would arise; and if GST had already been paid, no refund would be admissible.

List of Cases Cited

• • IMS Proschool (P.) Ltd. — 2018 (18) G.S.T.L. 241 (A.A.R. – GST) — Referred [Para 6]
    Interviewbit Software Services (P.) Ltd. — (2023) 8 Centax 256 (A.A.R. – GST – Kar.) = 2023 (76) G.S.T.L. 238 (A.A.R. – GST – Kar.) — Referred [Para 6]
    J.K. Papad Industries v. Union of India — (2024) 22 Centax 335 (Guj.) — Referred [Para 17]

List of Departmental Clarification Cited

• • Circular No. 245/02/2025-GST, dated 28-01-2025

List of Notifications Cited

• • Notification No. 12/2017-Central Tax (Rate), dated 28-06-2017
  • Notification No. 08/2024-CT(R), dated 8-10-2024
  • Notification No. 06/2025-CT(R), dated 16-01-2025