In view of above legal provisions we are of the view that where coaching services are provided by the applicant to the students, students shall be regarded as ‘recipient’ as consideration is payable by the students to the applicant. Similarly, Network partner shall be regarded as provider of service to the applicant (recipient). The place of supply in both the cases (i.e. services provided to the students and service provided to the applicant by the network partner) would be determined in the manner as discussed above. As discussed above the applicant has been incurring the cost of goods (i. e. printed material test papers, uniform, umbrellas, bags and other goods etc.) and service (coaching service etc.) supplied to the students, therefore, in light of Sections 15 of (he Act. the values of goods and value of service shall be the value of supply as charged in lump sum amount by the applicant from the students.
