Held - The appellant has a boarding school and it receives hostel fees from students in addition to the tuition fee and other charges. However, students who are day scholars and who do not opt to pay the hostel facility are not required to pay the hostel fees. The hostel facility cannot be provided without the provision of education services by a boarding school as it is not the case of the department and it cannot be that students who are not.....

Held - It is not in dispute that AMSL run the program under the DDU-GKY project, wherein the Boarding and Lodging facilities are to be extended by them to the students enrolled in the program. AMSL has engaged the applicant to provide the 'Hospitality services' and entered into an agreement with the applicant.

From the facts of the case it is seen that the applicant is to extend the services as per the 'Statement of Work' (SOW) which inc.....

Held - As per Section 2 (74) of the CGST Act the term “mixed supply” means two or more individual supplies of goods or services, or any combination thereof made in conjunction with each other by a taxable person for a single price where such supply does not constitute a composite supply.

The provision of hostel accommodation could be a principal supply but ancillary service food cannot be said to arise naturally with the princip.....

Held - Ruling per: Smt. K. Latha Member SGST:

Examination of the details, agreement and other documents reveals that the applicant Tvl. Healers ark Resources Private Limited is not providing accommodation and other services to Tvl Apollo Med skills Limited (AMSL) but only supporting Tvl. Apollo Med Skills in implementation of project under Deen Dayal Upadhyay Grameen Kaushaiya Yojana (DDU--GKY). The Hostel, Boarding and .....

Held - The appellant is mainly and principally engaged in imparting training/coaching to their students and thereby providing educational services, which is classifiable under SAC 9992-999293. The student who opts to take coaching from them stays in their hostel and pay hostel fees @ less than ₹ 200 per day or maximum ₹ 6000/- per month, in addition to the course charges as a package. It is also undisputed that they are charging ₹ 250/- .....

 Held - The provision of coaching/training provided by the applicant to their students along with the hostel facility qualifies as a composite supply as defined in Section 2 (30) of the CGST Act, 2017 and the tax liability on the composite supply has to be determined as per provisions of Section 8 (a) of the CGST Act, 2017. Therefore, the entire supply is to be treated as falling under SAC - 9992- 999293 - Commercial trai.....