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2026 Supreme(Online)(CESTAT) 1917

CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
P. K. Choudhary, Judicial Member, P. Anjani Kumar, Technical Member
Schoolnet India Limited – Appellant
Versus
Commissioner, Central Goods & Service Tax, Noida – Respondent


Advocates:
For the Appellants/Petitioners: B. L. Narasimhan
For the Respondents: Santosh Kumar

Table of Content
1. factual background of the ict@ school scheme and service tax history. (Para 1 , 2 , 14 , 15)
2. appellants argue services are bundled and exempt as education. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11)
3. revenue challenges bundling and seeks re-valuation of services. (Para 12 , 13)
4. defining education services and bundling under finance act, 1994. (Para 16 , 17 , 18 , 19 , 20 , 21 , 22)
5. education services are tax-exempt, either via negative list or notification. (Para 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36 , 37)
6. appeal of the assessee allowed; revenue appeal dismissed. (Para 38)

P. ANJANI KUMAR:

M/s School Net India Limited (SNIL, formerly known as ‘IL&FS Educational & Technology Service) arraign the impugned Order-in-Original dated 31.7.2020, vide Service Tax Appeal No. 70470 of 2020, for the reason that a demand of Rs. 39, 56, 57,281 was confirmed and Revenue is in appeal against the same order, vide Appeal No. 70045 of 2021, for the reason that a demand of Rs. 34, 11, 31,936 was dropped.

2. Brief facts of the case are that M/s SNIL are engaged in education, skill development, healthcare and cluster development for long term and

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