Madras High Court: Bharathidasan University v. Joint Commissioner of GST(ST-Intelligence), Trichy Division [2026 (2)
TMI 722]
The court upheld the GST demand on affiliation and inspection fees collected by the University, holding that
such services do not fall within the scope of the exemption provided to educational institutions under
Notification No. 12/2017.
The Court held that the GST exemption applies only to core educational services like admissions and
examinations. It was observed that affiliation is a separate, prior activity and cannot be covered under this
exemption. Relying on a strict interpretation of exemption provisions and GST circulars, the Court ruled that
affiliation services are taxable and not eligible for exemption, thereby rejecting the University’s plea.
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