Held - The “education” imparted by the Appellate would not lead to the obtaining a qualification recognised by the ICAI/ICWAI. Needless to say that the Appellant is not an affiliate of the said Institutes and hence would only be referred to as a coaching institute and not an educational institution.

The Appellant cannot claim the benefit of exemption as an Educational Institution providing Education as a part of a curriculum for obtaining a qualification recognized by any law for the time being in force under the Notification No. 12/2017.