GST Exemption not available on aircraft type rating training services to commercial pilots: AAR

The applicant stated that they are a Directorate General of Civil Aviation (DGCA) Approved Training Organisation (ATO) engaged in the business of providing type rating training on simulators for various fleet of aircraft to the trainees aspiring to obtain licenses and ratings from the DGCA; that the flight training services imparted by the applicant (ATO) enhances the skill and knowledge of trainees.

In view of the above, the applicant has sought advance ruling in respect of the following question:

Whether the supply of the aircraft type rating training services to commercial pilots in accordance with the training curriculum approved by the Directorate General of Civil Aviation for obtaining the extension of aircraft type ratings on their existing licenses would be covered under Sl.No.66(a) of the Notification No.12/2017-Central Tax (Rate) dated 28-06-2017 and Sl.No.66(a) of the Notification No.A.NI.-2-843/XI-9(47)/17-U.P.Act-1-2017-Order-(10)-2017 dated 30-06-2017, and thereby, exempted from levy of Central Goods and Service Tax and Karnataka Goods and Service Tax.

Advance Ruling:

The supply of the aircraft type rating training services to commercial pilots, in accordance with the training curriculum approved by the Directorate General of Civil Aviation for obtaining the extension of aircraft type ratings on their existing licenses, do not result into a qualification as the applicant imparts training and issues only course completion certificate and thus the impugned services are not covered under Sl. No. 66 (a) of the Notification No. 12/2017-Central Tax (Rate) dated 28.6.2017 and thus are exigible to GST under the CGST/KGST Act 2017.

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