GST Exemption on NSQF-Aligned Vocational Training: Kerala AAR Ruling in the Case of Packapeer Academy Pvt Ltd
Background and Overview
The Kerala Authority for Advance Ruling (AAR) has issued a significant ruling clarifying the GST treatment of vocational training services offered by accredited training bodies operating under NCVET-recognised Awarding Bodies. In the matter of In re Packapeer Academy Pvt Ltd (GST AAR Kerala), the Authority held that the "Junior Software Developer" course conducted by the assessee qualifies for complete GST exemption under Entry No. 69(e)(iii) of Notification No. 12/2017-Central Tax (Rate), as amended with effect from 10.10.2024.
This ruling carries broad relevance for IT training institutions, vocational academies, and skill development organisations that operate as training partners under NASSCOM or other NCVET-recognised Awarding Bodies.
About the Assessee
M/s. Packapeer Academy Pvt Ltd is registered under GST and operates from Room No. III/9, 3rd Floor, SDF Building (Neo Space II), Kinfra Techno-Industrial Park, Calicut University (PO), Kakkancheri, Malappuram – 673635. The assessee conducts both offline and online training programmes under its brand name "Brototype", covering a range of software development and IT-related skill courses.
On 22nd May, 2025, the assessee entered into a Memorandum of Understanding (MoU) with the IT-ITeS Sector Skills Council (SSC NASSCOM), which functions as an integral part of the National Association of Software and Service Companies (NASSCOM). Through this MoU, the assessee became an accredited training partner of IT-ITeS SSC NASSCOM.
IT-ITeS SSC NASSCOM holds the status of an Awarding Body recognised by the National Council for Vocational Education and Training (NCVET), as confirmed by an order of NCVET dated 11.11.2022. The Awarding Body is responsible for formulating assessment criteria, conducting assessments, and issuing certificates to successful candidates via the NSDC Skill India portal.
The Course in Question
The specific training programme forming the subject matter of the advance ruling application is the "Junior Software Developer" course, which carries the following attributes:
- Qualification Pack Code: SSC/Q0508
- NSQF Level: 4
- Approval Authority: National Skills Qualification Committee (NSQC)
- Qualification Package Status: Approved by NCVET
The assessee submitted that this course is aligned with the National Skill Qualifications Framework (NSQF) and is backed by an NCVET-approved Qualification Pack. Under the MoU, the assessee is responsible for enrolling candidates, delivering training, and facilitating the assessment process in accordance with NASSCOM's prescribed guidelines.
Questions Referred for Advance Ruling
The assessee approached the Kerala AAR seeking clarity on two specific questions:
Whether the training services provided in respect of the "Junior Software Developer" course, conducted in association with NASSCOM (an Awarding Body recognised by NCVET) and aligned to the NSQF, are covered under
Sl. No. 69ofNotification No. 12/2017 – Central Tax (Rate)dated 28.06.2017, as amended, and are thereby exempt from the levy of GST.If exempt, whether the exemption extends to the entire course fee collected from students towards such vocational training programme.