"A" is an educational institution (Medical college) and also has a hospital as a mandatory requirement that medical colleges should have a hospital. It is registered under the societies registration act and also an approved institution u/s 12AA and 10(23C)(vi) of the Income Tax Act, 1961 providing educational qualification recognized by law. As the notification no 25/2012, services provided to/by an educational institution is exempt from service tax liability. As far as "A" is concerned, educational service is the main service provided whereas medical service provided by the hospital are only ancillary in nature. But hospital charges at the same rate charged by other private hospitals and consequently the turnover of the hospital is more than the turnover from the educational institution. My question here is, are the services provided to "A" in relation to hospital activities exempt from service tax as per the above mentioned notification?
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