TaxTMI 
TaxTMI 
2018 (7) TMI 1495
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....d as 'IELTS') is a highly regarded English Language proficiency test developed, managed and owned by the British Council, U.K. (hereinafter referred to as 'BCUK'). 2. BCUK furthers its charitable, educational and cultural relations by offering to private individuals, students and other partner organizations a broad range of examination services globally which support proficiency in English Language and other educational and professional qualifications. 3. The examinations which are operated under global arrangements administered centrally by BCUK include 'IELTS','ESOL' and school exams provided by UK Exam Boards. BCUK also administers examinations globally on behalf of certain professional bodies and UK universities. 4. I....
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.... in India: (vii) To recruit, train and monitor invigilators, examiners and test paper markers for the IELTS tests, in accordance with the standards set by BCUK and their own administrative and management staff; (viii) To periodically inspect the quality of test centres and provide documented evidence on their performance. 7. Under the agreement it is specified that the Applicant will provide Exam Support Services to BCUK for which BCUK will pay the charge to the Applicant as follows: (a) Exam Support Services provided by the Applicant will be billed to BCUK calculated at cost plus mark up determined in accordance with relevant transfer pricing regulations, (b) The cost will include costs of test centres and dedicated staff, directly re....
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.... applicable on these exam support services? as these were covered under the provision 97(2)(e) of the CGST/HGST Act, 2017. The third question involved determination of place of supply which was beyond the scope of the Authority for Advance Ruling as its rulings were specific to the Stale only and therefore, the application so far it sought determination of place of supply was not admitted. As regards the questions admitted the answer to the first question itself will provide answer for the second question as the Statute itself is clear regarding taxability of composite and mixed supplies. As per the copy of agreement provided by the Applicant and placed on record, the services proposed to be provided by them to BCUK are divided in three ....
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....ational consulting 2. Educational guidance counselling services 3. Educational testing evaluation services 4. Educational testing services 5. Organization of student exchange programmes It had been argued that the conduct of IELTS exam by them is education testing evaluation services and thus covered under education support services as per the UNCPC schemes as above. These present had also argued for considering their question for determination of place of supply and had drawn our attention to several case laws and particularly to section 2 (6) of the IGST Act. After hearing these present in detail the decision on admissibility of the application was pronounced and as regard decision on question 1 & 2, on which the application was ad....
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....lowing: (i) To source and manage the running of suitable test centre venues in India for the examination; (ii) To receive registration information from BCUK and its registration agents for IELTS; (iii) To maintain supplies of Test Materials for administration and comply with security requirement set by BCUK and relevant external exam boards in relation to logging in and out. To distribute test materials to candidates on the test day and collect them after test administration for processing; (iv) To manage test administration and logistics for test days, including scheduling of the Applicant's staff and liaison with the test centres; (v) To provide back office support in relation to financial controls and accounting processes ....