The applicant is providing various types of courses, some of which are explicitly exempted under GST and tax is payable on fees towards other courses including Executive Post Graduate Programme (EPGP), which is a one year residential programme. Indian Institutes of Management Act 2017 promulgated with effect from 31.01.2018, has declared IIMs as institutions of National importance and by Section 7(f) of the Act.

The Applicant sought Advance Ruling on following issues:

1. Whether the course Executive Post Graduate Programme in Management (EPGP), after enactment of Indian Institute of Management Act 2017 notified effective from 31st January 2018, is exempted from Goods and Service Tax?

2. In case of exemption to EPGP, will total amount of fees collected towards EPGP for the academic session 2018-19 is exempted, whether collected before or after enactment of IIM Act 2017 or only amount collected after enactment of IIM Act 2017?

Entry No.67 of Notification 12/2107-Central Tax (Rate) is exclusively for providing exemption to the services provided by Indian Institutes of Management.


Heading 9992

Services provided by the Indian Institutes of Management as per the guidelines of the Central Government to their students by way of following educational programmes, except Executive Development Programme- 
(a) Two year full time Post Graduate Programmes in Management for the Post Graduate Diploma in Management, to which the admissions are made on the basis of Common Admission Test (CAT) conducted by the Indian Institute of Management;

(b) Fellow Programme in Management;

(c) Five year integrated programme in Management.



Services provided by the Applicant have a specific mention under Entry No.67 to the Notification 12/2107-Central Tax (Rate) and corresponding notification under MPGST Act, 2017, and therefore, there is no good reason to take shelter of a general entry (entry no.66) just to bring the Executive Post Graduate Programme under the ambit of exemption.

CRUX: 1. the Executive Post Graduate Programme will not be eligible for exemption from GST as the same has been categorically excluded from exemption under Entry No.67 to the Notification No.12/2017-Central Tax (Rate).

2. The Executive Post Graduate Programme being conducted by the Applicant shall be chargeable to GST, irrespective of enactment of IIM Act 2017.