Services provided by Indian Entity to foreign universities for student admissions, under direct contract and consideration, are not "intermediary" supplies

Last updated: 13 September 2025

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The Supreme Court has dismissed the Revenue's appeal, confirming that Indian education consultants providing services directly to foreign universities for student admissions are undertaking 'export of services'. The court affirmed the Bombay High Court's decision, stating that these services, when contracted and paid for directly by the foreign university, do not constitute 'intermediary services'. Consequently, these transactions are eligible for IGST refunds under Indian GST law.

Court :
Supreme Court of India

Brief :
The Hon'ble Supreme Court in the case of The Union of India & Ors V. KC Overseas Education Pvt Ltd Nagpur [SLP(C) Nos. 21104-21105/2025, order dated August 25, 2025] dismissed the Revenue's special leave petition, thereby affirming the Bombay High Court's findings and upholding the IGST refund entitlement. The Court held that services provided by Indian education consultants to foreign universities for facilitating student admissions, where the contractual relationship and consideration are directly between the Indian entity and the foreign university, do not qualify as "intermediary services" but instead constitute "export of services" under the IGST Act. Accordingly, such transactions are eligible for IGST refund under Indian GST law.

Citation :
SLP(C) Nos. 21104-21105/2025, order dated August 25, 2025

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Attached File : 671907_5864_sc_bhc_overseas_education_pvt_ltd_nagpur.pdf

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Judgement posted by

Bimal Jain

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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