As per case facts, Bharathidasan University challenged GST liability notices for affiliation fees, arguing exemption under Notification No. 12/2017-CTR as services related to education. The Department maintained these fees were ... taxable. The matter was referred to a High Court Division Bench due to conflicting judicial opinions among Single Judges. The central legal question for the Division Bench was: "Whether affiliation charges collected by an University from the affiliating Institution is amenable to levy of GST?". Finally, the Division Bench held that affiliation fees do not fall within the exemption, as granting affiliation is not considered part of admission or conduct of examination. Therefore, such fees are amenable to GST.