The petitioner contended that the proposed GST levy and demand on affiliation fees was unsustainable and that affiliation did not constitute a taxable service. In the earlier judgment, the Court had allowed the writ petitions, held the proposed GST levy and demand on affiliation fees unsustainable, and quashed the show cause notice dated 26.12.2023. Issue (ii): Whether Affiliation Fees Constitute Consideration-Affiliation is compulsory for colleges; there is no element of choice, bargaining, or reciprocity. Levy of GST on affiliation fees results in indirect taxation of education, which is impermissible. Levy and collection of GST on affiliation fees is illegal and unsustainable.