ORDER :

Arun Monga, J.

1. Rajasthan Technical University, a State university set up by Government of Rajasthan, is before this court, aggrieved against the impugned Show Cause Notice dated 26.12.2023 and; consequential proceedings vide which the act of affiliation granted by it to the affiliate colleges has been included in the statutory term “service” and; thus tax has been imposed on the University under the provisions of CGST, 2017 and directed to pay service tax with interest and penalty.

2. Case of the Petitioner University is that the impugned Show Cause Notice has been issued in contravention of the provisions of the Central Goods and Services Tax, 2017 (CGST Act). and Rules framed there under. It is also arbitrary and violative of Articles 14, 19(1)(g), 265 and 300A of the Constitution of India. More of it later.

2.1. The controversy that warrants adjudication by court is whether or not the affiliation fee charged by a University, for grant of affiliation to its constituent college, is subject to levy of service Tax under CGST Act.

2.2 Bunch of petitions have been filed as per Appendix ‘A’ wherein similar controversy is involved and vide this common order and judgment all of tho