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5.5 We observe that appellant admittedly is registered under Section 12AA of the Income Tax Act. The section provides that non-profit organisations like charitable trusts, welfare societies, NGOs, religious institutions etc. are entitled to tax exemption. The certificate of appellants' registration as a charitable trust is also on record. We rely upon the decision of Hon'ble Supreme Court in the case of Ahmedabad Urban Development Authority (supra) wherein it has been held that the income and receipts of statutory regulatory ST/53090/2016, ST/51947/2022 bodies which are for instance, tasked with exclusive duties of prescribing curriculum, disciplining professionals and prescribing standards of professional conduct, are prima facie not business nor commercial receipts, if the regulatory body is to be considered as one with "charitable purpose" eligible for exemption under the Income Tax Act. We observe that appellant admittedly is registered under Section 12AA of the Income Tax Act. The section provides that non- profit organisations like charitable trusts, welfare societies, NGOs, religious institutions etc. are entitled to tax exemption. The certificate of appellants' registration as a charitable trust is also on Further, there is department's own Circular No. 177/09/2022- TRU dated 03.08.2022 wherein it has been held that all services supplied by an 'educational institution' to its students are exempts from GST. Consideration charged by the educational institutes by way of entrance fee for conduct of entrance examination is also exempt. The exemption is wide enough to cover the amount or fee charged for admission or entrance, or amount charged for application fee for entrance, or the fee charged from prospective students for issuance of eligibility certificate to them in the process of their entrance/admission to the educational institution. Services supplied by an educational institution by way of issuance of migration certificate to the leaving or ex-students are also covered by the exemption. Accordingly, such activities of educational institution are also exempt. Accordingly, it is clarified that the amount for fee charged prospective students for entrance or admission, or for issuance of eligibility certificate to them in the process of their entrance/admission as well as the fee charged for issuance of migration certificates by educational institutions to the leaving or ST/53090/2016, ST/51947/2022 ex-students is covered by exemption under Sl. No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017. 5.6 A prior circular also bearing no. 89/7/2006-ST dated 18.12.2006 has clarified that statutory functions performed in terms of specific responsibility assigned to a sovereign/public authority or any authority under law in force does not constitute provision of taxable service to a person and therefore no service tax is leviable on the activities of such authority. CESTAT Mumbai while relying upon this circular in the case of MIDC Vs. CCE reported as 2014 TIOL 2022 (Tri.-Mum.) has held that the fee collected by the authority constituted under provisions of law for performing such activity which is in nature of compulsory/statutory levy as per the provisions of relevant statute and that it is deposited in the government treasury, such activity is undertaken as mandatory and statutory function and thus, do not come under the ambit of taxable service. Hence, no service tax is leviable on such activity. The Hon'ble Supreme Court in Ahmedabad Urban Development Authority (supra) has clarified that the income and receipts of statutory regulatory bodies which are for instance, tasked with exclusive duties of prescribing curriculum, disciplining professionals and prescribing standards of professional conduct, are prima facie not business or commercial receipts. However, this is subject to the caveat that if the assessing authorities discern that certain kinds of activities carried out by such regulatory body involved charging of fees that are significantly higher than the cost incurred (with a nominal mark-up) or providing other facilities or services such as admission forms, coaching classes, registration processing fees, etc., at markedly higher prices, those would constitute commercial or business receipts. In that event, the ST/53090/2016, ST/51947/2022 overall quantitative limit prescribed in the proviso to Section 2(15) (as amended from time to time) has to be complied with, if the regulatory body is to be considered as one with 'charitable purpose' eligible for exemption under the IT Act. Like statutory authorities which regulate professions, statutory bodies which certify products (such as seeds) based on standards for qualification, etc. will also be treated similarly. The original adjudicating authority has confirmed the demand holding that the appellants are neither covered under Mega Exemption Notification nor under the negative list, are therefore not sustainable.