GST Vidhi | GST Advance Ruling


M/s Sisinty Private Limited Vs. Authority for Advance Ruling, Karnataka (AAR No. KAR ADRG 27/2025)

GST On Market Led Fee-Based Services” (MLFBS) scheme  / GST Exemption on NSDC-Aligned Courses

Background of the Case

M/s Sisinty Private Limited is a Bengaluru-based private company operating an online upskilling platform aimed at improving the technical capabilities of working professionals. The company has collaborated with the National Skill Development Corporation (NSDC) as an Approved Training Partner under the “Market Led Fee-Based Services” (MLFBS) scheme. This initiative is a part of NSDC's broader agenda to enhance skill-based education through public-private partnerships.

In this context, the company approached the Authority for Advance Ruling (AAR) seeking clarity on whether the services it provides in association with NSDC are exempt from GST.

·       AAR No. KAR ADRG 27/2025

·       Date: 28th July 2025

·       Court: Authority for Advance Ruling, Karnataka

·       Applicant: M/s Sisinty Private Limited

 

Questions Before the Authority

1.    What is the applicable rate of GST on services provided under the Market Led Fee-Based Services Scheme?

2.    Whether the applicant is eligible for exemption under Entry No. 69 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017?

Applicant's Submissions and Interpretation

The applicant made the following key submissions:

  • They are recognized as an Approved Training Partner by NSDC.
  • The training programs are conducted under the Market Led Fee-Based Services Scheme, which is an NSDC-implemented scheme.
  • They are responsible for uploading candidate details on the Skill India Portal (SIP), ensuring monitoring of targets and compliance as per the NSDC's terms.
  • They contended that their services fall within the exemption scope of Entry No. 69 of Notification No. 12/2017, which provides GST exemption for services by approved NSDC training partners.
  • The applicant cited similar advance rulings like those in the cases of M/s Nxtwave Disruptive Technologies Pvt. Ltd. and M/s Interviewbit Software Services Pvt. Ltd., where GST exemption was granted for identical NSDC-aligned training services.

According to the applicant, the following two conditions were satisfied to avail GST exemption:

  • The service provider (Sisinty Pvt. Ltd.) is an approved training partner of NSDC.
  • The services are offered in relation to a scheme implemented by NSDC.

Proceedings & Personal Hearing

The applicant was represented by Chartered Accountant Mr. Swagath Killamasetty during the personal hearing held on 16th June 2025. He reiterated the facts and legal position submitted in the application.

Legal Analysis by the Authority

The AAR analyzed the scope of Entry No. 69 of Notification No. 12/2017-Central Tax (Rate) as amended by Notification No. 08/2024 dated 08.10.2024. The key points of the exemption entry include:

  • Services must be provided by:
    • NSDC itself,
    • A Sector Skill Council,
    • An assessment agency,
    • An NSDC-approved training partner, etc.
  • The services must be in relation to:
    • National Skill Development Program,
    • NSDC-implemented scheme,
    • Any National Skill Qualification Framework (NSQF)-aligned qualification, etc.

AAR’s Findings and Decision

After examining the facts, documents, and submissions, the Authority concluded:

  • M/s Sisinty Private Limited is indeed an NSDC-approved training partner.
  • The services offered under the Market Led Fee-Based Services Scheme fall squarely within the ambit of schemes implemented by NSDC.
  • Both criteria for GST exemption under Entry No. 69 are fully satisfied.

Ruling:

1.    Rate of GST: NIL (Exempted) for services under the MLFBS Scheme.

2.    Eligibility for Exemption: The applicant is eligible for GST exemption under Entry No. 69 of Notification No. 12/2017-Central Tax (Rate), as amended.

Conclusion

The ruling brings welcome clarity for private ed-tech companies and training entities engaged in skilling initiatives in partnership with NSDC. The decision confirms that services rendered under NSDC-approved schemes by registered training partners are exempt from GST, ensuring affordability and promotion of skill-based training in India.

This ruling reinforces the government’s aim to encourage vocational training and upskilling initiatives by removing the GST burden for NSDC-aligned programs.

Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.

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