Jayanta Kumar Biswas ( 1 ) THE tax authorities informed the petitioner that in view of provisions of the Finance Act, 1994, Section 65 (27) his commercial training centre (a motor training school) would be covered for payment of service tax. After giving such decision the competent authority initiated the requisite proceeding by issuing summons under the Central Excise Act, 1944, Section 14. At such stage this writ petition has been taken out. ( 2 ) ACCORDING to the petitioner, for the motor training school run by him no service tax is payable, because his school that issues a certificate recognised by law in force will stand excluded in view of provisions of the same Section 65 (27), which is : " (27) "commercial training or coaching centre" means any institute or establishment providing commercial training or coaching for imparting skill or knowledge or lessons of any subject or field other than the sports, with or without issuance of a certificate and includes coaching or tutorial classes but does not include pre-school coaching and training centre or any institute or establishment which issues any certificate or diploma or degree or any educational gratification recognised by law for the time being in force;" ( 3 ) THE undisputed facts are these. The petitioner runs a school for imparting instructions in driving of motor vehicles; and for that purpose he has obtained licence in terms of provisions of the Motor Vehicles Act, 1988 and the Central Motor Vehicles Rules, 1989. In view of provisions of the said Act, Sections 9 and 12, and Rules 14 and 27, his school issues a certificate in prescribed form to a person who is trained by it; and the holder of such certificate can use it for making application for driving licence. While, in view of provisions of Section 9 (4) of the said Act, an application for licence to drive a transport vehicle must be accompanied by it, is not so in other cases. ( 4 ) THE question that has arisen for decision is whether the certificate issued by the motor training school of the petitioner is such a certificate as is mentioned in Section 65 (27) of the Finance Act, 1994 for indicating which centre or institute or establishment will remain outside the service tax net. ( 4 ) THE question that has arisen for decision is whether the certificate issued by the motor training school of the petitioner is such a certificate as is mentioned in Section 65 (27) of the Finance Act, 1994 for indicating which centre or institute or establishment will remain outside the service tax net. If the answer is in the affirmative, then the petitioner is right that the tax authorities are wrong. ( 5 ) COUNSEL for the petitioner argues that a motor training school like the one of the petitioner, imparts training in driving of motor vehicles following the manner, syllabus and course that are specified and prescribed by the rules made by the central Government in exercise of power conferred on it by the Motor Vehicles Act, 1988, Section 12, and then issues a certificate in prescribed form in terms of Rules 14 (e) and 27 (d) of the Central Motor vehicles Rules, 1989; and therefore, there can be no dispute that the certificate so issued, being recognised by law in force, is such a certificate as is mentioned in said Section 65 (27) for indicating the class left uncovered by the service tax net. ( 6 ) COUNSEL for the respondents responds by saying that except for obtaining licence to drive transport vehicle, in all other cases regarding grant of licence the certificate issued by a motor training school in terms of Rule 27 (d) is of little significance. He argues that the certificate issued by the motor training school of the petitioner is used, if at all, only for making application for driving licence, and hence it is not such a certificate as is contemplated by Section 65 (27) of the Finance Act, 1994 for keeping certain centres or institutes or establishments outside the service tax net. ( 7 ) AFTER hearing Counsel for the parties, and after considering the relevant provisions of law, I am minded to agree with Counsel for the respondents. ( 8 ) TO my mind, the three associated words, "certificate," "diploma," and "degree," followed by the expression "any educational qualification," used in Section 65 (27) of the Finance Act, 1994, must be understood to have been used in their cognate sense. The order of the words and the expression is also very significant. ( 8 ) TO my mind, the three associated words, "certificate," "diploma," and "degree," followed by the expression "any educational qualification," used in Section 65 (27) of the Finance Act, 1994, must be understood to have been used in their cognate sense. The order of the words and the expression is also very significant. A diploma or degree, denoting, as a matter of fact, only higher educational qualifications, can be obtained only by a person who possesses a certificate showing the requisite basic educational qualification. The higher qualifications are indicated by the words diploma or degree, whenever such words happen to be used instead of the specific higher qualifications. ( 9 ) IT seems to me that the three words and the expression all relate to educational qualifications, that is, to qualifications which can be acquired only after prosecuting educational courses, in a word, indicating academic achievements. But a certificate issued by a motor training school relates only to driving of motor vehicles, and it has nothing to do with any academic achievement ; it can be issued even to a person who received training in driving motor vehicles, but never had any occasion or opportunity to go to a nursery or primary school. ( 10 ) A certificate issued by a motor training school or centre has to relation to the arts of reading, writing and ciphering; it, by no means, fits in with the meanings denoted by the words "diploma" and "degree. " It is issued and used only for making an application for driving licence; it has no other utility. It does not possess the features and value of a certificate or diploma or degree (regarding any educational qualification) that can be used on numerous occasions by its holder for numerous purposes, employment being the principal one. ( 11 ) FOR the reasons I am unable to agree with Counsel for the petitioner that his client is not liable to pay service tax. In view of the unambiguous language of Section 65 (27) of the Finance Act, 1994, defining the expressions "commercial training or coaching centre," there can be no doubt that the motor training school of the petitioner, providing commercial training for imparting instructions in driving motor vehicles, with issuance of a certificate, is a commercial training centre falling within the sinkers of the service tax net. ( 12 ) AS a result, I do not find any merit in the writ petition; and hence it is dismissed. There will be no order for costs in it. ( 13 ) ALL parties are to act on a signed xerox copy of this dictated order and also on an urgent certified xerox copy thereof, both to be supplied on the usual undertakings.