Levy of GST— The present appeal has been filed against the Advance Ruling order.

The Appellant is an approved NEEM (National Employability Enhancement Mission) Facilitator under the All India Council for Technical Education (NEEM) Regulations, 2017. The objective of NEEM is to offer on the job practical training to enhance employability of a person pursuing Post-Graduate/Graduate/Diploma in any technical or non-technical stream or a person who has discontinued studies after class 10. 

The Appellant sought a ruling from the lower Authority as to whether the stipend amount reimbursed by the industry partner to the Appellant which is used solely for the purposes of paying the trainees in accordance with the NEEM Regulations can be excluded from the value of service supplied by them since they are acting as a 'pure agent' of the industry partner. 

The lower Authority gave a ruling in the negative stating that the Appellant failed to fulfill the conditions stipulated in Rule 33 of the CGST Rules and hence did not qualify to be a pure agent.

The limited issue for determination is whether the Appellant is acting as a 'pure agent' of the industry partner to the extent of reimbursement received towards stipend paid to trainees as part of the training agreement.

Held that— This authority uphold the order passed by the Advance Ruling Authority and the appeal filed by the Appellant M/s. Teamlease education foundation, stands dismissed on all accounts.