2026-VIL-140-AAR
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SGST Advance Ruling Authority

GST – Rajasthan AAR - Applicability of e-invoicing Notification No. 13/2020-Central Tax dated 31 March 2020 to coaching services through registered third party recipients - Determination of recipient and place of supply - Applicant is educational institution providing commercial coaching for competitive exams receiving fees from parents guardians or business enterprises some of whom are GST registered - Applicant seeks ruling on whether e-invoicing notification applies when registered third party furnishes GSTIN for coaching services rendered to student beneficiaries and whether supplier must verify recipient's ITC eligibility - HELD - Notification No.13/2020 dated 21.03.2020 read with Rule 48(4) CGST Rules requires e-invoice generation for registered persons whose turnover exceeds prescribed threshold in respect of supplies to registered recipients. Applicability of notification is confined to genuine business-to-business supplies where recipient is person liable to pay consideration under contract of supply. Identity of recipient under Section 2(93)(a) CGST Act is determinative of place of supply and must be identified in relation to actual supply - Where coaching service is rendered to and consumed by student enrolled student integral to recipient identity and cannot be divorced therefrom. Liability to pay consideration must flow from being party to contract of supply not merely from being source of funds. Mere furnishing of GSTIN by third party does not transform substance of business-to-consumer educational supply into B2B supply - E-invoicing obligation attaches only to genuine B2B supplies made to registered recipient where person furnishing GSTIN is person liable to pay consideration under contract – The supplier's obligation under notification operates independently of recipient's credit eligibility. However applicant's own acknowledgement that coaching fees appear personal in nature engages bar under Section 17(5)(g) CGST Act. No finding warranted that endorses characterizing personal educational expenditure as B2B supply. Ruling confined to facts as pleaded – The e-invoicing applies to genuine B2B supplies where recipient is contractually liable person and determination of each transaction requires factual examination – Ordered accordingly
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