2026-VIL-81-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR - Exemption to Training Services provided by NSDC Approved Training Partner – Applicant is an NSDC approved training partner, provides digital marketing training courses as part of the Government's Skill India initiative - Prior to the changes in law, the training services provided by the applicant were treated as exempt supplies. However, due to amendments in 2024 and their subsequent reversal in 2025, there was ambiguity about the GST applicability during the interim period - Whether the training services provided by the applicant as an MSDE/NSDC affiliated Training Partner imparting NSQF-aligned digital marketing courses to students are exempt from GST under Sl. No. 69 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017, as amended from time to time (including by Notification Nos. 08/2024-CT(R) and 06/2025-CT(R)) – HELD – The Entry No. 69 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017, as amended exempts services provided by a training partner approved by the NSDC in relation to the National Skill Development Programme implemented by NSDC or any other scheme implemented by NSDC. Since the applicant is an NSDC approved training partner and the digital marketing course it provides is aligned with the National Skills Qualifications Framework (NSQF) and is part of the Government's Skill India mission, the applicant's services fall within the scope of the exemption - However, during the intervening period from 10.10.2024 to 15.01.2025, when the exemption for NSDC approved training partners was temporarily withdrawn, the applicant's liability to pay GST would be on an 'as is where is' basis. This means that if the applicant had not paid GST during this period, it would not be required to do so now, but if it had paid, the payment would be allowed to stand - The training services provided by the applicant are exempt from GST under Entry No. 69 of Notification No. 12/2017-Central Tax (Rate) dated 28-06-2017, as amended, except for the intervening period from 10.10.2024 to 15.01.2025, where the liability would be on an 'as is where is' basis – Ordered accordingly
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