In this case, Muniyasamy Abhinaya (who was not registered under GST) sought a ruling on his proposed transport service. He submitted that the service will be provided under agreements with certain schools. The bus and van permits will be in the name of these schools. He will be receiving payments for pick-up and drop-off of students directly from parents, while the school will pay him for providing such services to their staff.
The AAR bench held that these services will be exempt, as detailed in a 2017 notification. This notification exempts transportation services to educational institutions.