The Rajasthan High Court has held that affiliation fees charged by schools are not exigible to GST, extending its own Division Bench ruling in Rajasthan Technical University v. Union of India (D.B. CWP No. 9556/2024, decided 23.02.2026) — which had declared that grant of affiliation by a university is a statutory and regulatory function, not a supply of service, and that affiliation fees are exempt under Entry 66 of Notification No. 12/2017-CT (Rate). The ruling by Justice Pushpendra Singh Bhati and Justice Praveer Bhatnagar in D.B. CWP No. 15963/2025 (Adarsh Vidhya Mandir Senior Secondary School, decided 17.08.2026) quashed the impugned circular and notice along with all consequential proceedings.
The court noted that the Rajasthan Technical University decision had specifically considered the nature of affiliation of schools with the Central Board of Secondary Education and recorded that the conditions governing such affiliation — adherence to prescribed curriculum, maintenance of academic and infrastructural standards, and presentation of students for examination — are, in substance and effect, pari materia with those governing affiliation of colleges with a university. The Revenue's counsel fairly conceded that the reasoning and conclusions in RTU would equally govern the present case. The court also noted that Revenue Notification No. 14/2018 had already deemed Central and State Educational Boards to be 'educational institutions' for the purpose of conducting examinations, and any attempt to deny universities or affiliated schools similar treatment would be manifestly arbitrary.
- 2026-juristway.com-2470-HC(Rajasthan)-GST | High Court of Rajasthan | D.B. CWP No. 15963/2025 | 17.08.2026