The Kerala Authority for Advance Ruling has delivered a comprehensive multi-issue ruling holding that a private coaching institute providing preparatory coaching for CA, ACCA, CMA (India/USA), CS and CPA (USA) examinations does not qualify as an ‘educational institution’ under clause (y) of paragraph 2 of Notification No. 12/2017-CT (Rate) and is not eligible for exemption under Serial No. 66. The ruling by Members Jomy Jacob and Mansur M.I. in KER/18/2026 (M/s Learnfluence Education Pvt. Ltd., decided 21.08.2026) addresses five distinct questions spanning taxability of coaching, exam fee collection, study materials, forex fluctuations and training partner fees from universities.
On the coaching services, the AAR held that the applicant provides coaching and support services to students for courses conducted by professional bodies, but neither conducts examinations nor awards qualifications — the recognised qualification is awarded by ACCA, IMA (USA) or the collaborating university. On study materials, the supply of printed books, digital resources and recorded lectures as part of the coaching package constitutes a composite supply with coaching as the principal supply, and cannot be artificially segregated to claim book exemption under Entry 119. On exam fees collected from students and remitted to foreign bodies, the applicant failed to establish pure agent status under Rule 33. On forex fluctuations, the AAR held that the differential amount retained is not consideration for any supply, as exchange rate movements could result in gains or losses and have no certain nexus with services rendered. On training partner fees received from universities, the services are taxable at 18% under Heading 9992 as the applicant does not qualify under Entry 66(a) or 66(b). The ruling follows the Kerala AAAR’s decision in Logic Management Training Institutes.
- 2026-juristway.com-2636-AAR(Kerala)-GST | AAR Kerala | KER/18/2026 | 21.08.2026