Affiliation Fees Under GST: Relief for Universities or Continuing Litigation?

Vivek Jalan | Last updated: 25 April 2026

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The applicability of GST on university affiliation fees remains a contentious issue. While a Rajasthan High Court ruling suggested relief by classifying these fees as statutory levies rather than consideration for services, a Madras High Court ruling and a GST circular have indicated that these fees are taxable. The core of the dispute lies in whether affiliation is a business service or a regulatory function, and how it relates to exempt educational activities.

The Rajasthan Technical University case RAJASTHAN TECHNICAL UNIVERSITY, KOTA Vs UNION OF INDIA [2026-VIL-206-RAJ] against the Union of India provides some relief on the applicability of GST to statutory levies. At the heart of the dispute was whether affiliation fees charged by a university to colleges could be treated as "consideration" for a supply of service under Section 7 of the CGST Act. The court examined the statutory framework closely, noting that Section 7(1)(a) requires a supply to b

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1 Year PLAN

1999

(Excl. of GST ₹359)

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2 Years PLAN

3499

(Excl. of GST ₹629)

3 Months PLAN

999

(Excl. of GST ₹179)

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About the Author

Vivek Jalan

DESIGNATED PARTNER

Mr. Vivek Jalan is a FCA, Qualified LL.M (Constitutional Law) and LL.B. He is the Chairman of The Fiscal Affairs and Taxation Committee of The Bengal Chamber of Commerce and Industry. He is the Convenor on Indirect Taxes of the CII- Economic Affairs and Taxation Committee (ER); He is also a visiting faculty for Indirec ... Read more

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