High Court of Rajasthan10 July 2026

Surendera Group of Institutions v. Union of India

For assessee

D.B. CIVIL WRIT PETITION NO. 7287 OF 2026

The ruling in brief

Where petitioner-college paid affiliation fees to university and demand for GST on such fees was raised, grant of affiliation being a statutory and regulatory function did not constitute supply, affiliation fees were not consideration for taxable activity and were exempt under Entry 66 of Notification 12/2017-CT (Rate), thus GST demand was unsustainable and refund was directed if collected

Provisions considered

Section 9, read with sections 7, 54 and 56, of Central Goods and Services Tax Act, 2017/Rajasthan Goods and Services Tax Act, 2017

Related rulings

Supreme Court21 Sept 2026

For revenue

Matrix Cellular (international) Services (P.) Ltd. v. Principal Commissioner, State Tax, Delhi

SLP dismissed against review petition of High Court holding that where assessee withdrew refund application after issuance of deficiency memo and later sought interest for that disputed period in review petition on ground of error apparent, as no error or mistake was found in earlier judgment denying interest for that period, review petition was not maintainable and not considered on merits

GSTAT Raipur22 Sept 2026

For assessee

Cent Bank Home Finance Ltd. v. Commissioner, State Tax

Where appellant, a lender of housing loans, faced demand for GST on loan recoveries but invoked exemption under Notification No. 12/2017-CTR Entry 27 for first time before Tribunal, exemption applied as pure legal plea could be raised at any stage and recovery of loan amounts qualified as exempt service under Entry 27 GST: Where a housing loan lender claimed that receipts treated as taxable supply were actually recoveries of principal from written-off housing loan accounts and supported this with bank records showing deposits and SARFAESI charges, failure by revenue to consider admissible certified evidence warranted remand for production and consideration of such documents for just determination of exemption claim

Bombay High Court10 Sept 2026

For assessee

Dharma Productions (P.) Ltd. v. State of Maharashtra

Where film producer gave licensed rights to distributors to broadcast and show cinematographic films for a limited term and supplied content via encrypted hard disks or electronic links without providing software, same was to be classified as temporary licensing of IPR under SAC 997332 taxable at 12 percent applied, and not as supply of information technology software taxable at 18 percent since delivery mode and content format did not satisfy statutory classification for software. GST: Where petitioner gave licensed cinematographic rights to distributors and paid GST at 12 percent under SAC 997332 before CBIC circulars clarified overlap between 12 percent (SAC 9973) and 18 percent (SAC 9996) rates, such circulars would be binding and applicable to entire licensing chain; so confining benefit only to distributor-exhibitor transaction and not to producer-distributor transaction was contrary to law and not justified

Related rulings

Supreme Court21 Sept 2026

For revenue

Surendera Group of Institutions v. Union of India

The ruling in brief

Provisions considered

Surendera Group of Institutions v. Union of India

The ruling in brief

Provisions considered

Read the full analysis

Read the full analysis

Matrix Cellular (international) Services (P.) Ltd. v. Principal Commissioner, State Tax, Delhi

Cent Bank Home Finance Ltd. v. Commissioner, State Tax

Dharma Productions (P.) Ltd. v. State of Maharashtra