2026-VIL-88-AAR

SGST Advance Ruling Authority

GST – Karnataka AAR - Applicability of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 on charitable activities - Whether the services in relation to conducting emergency care and life support courses for medical, nursing, and allied healthcare students qualify as "charitable activities" by way of "public health through public awareness of preventive health" and exempt from GST – HELD - The Authority held that the activities undertaken by the applicant do not qualify as "public health by way of public awareness of preventive health" under paragraph 2(r) of the notification, which defines "charitable activities". The courses offered by the applicant, though aimed at imparting emergency care skills, are in the nature of structured professional training and skill development programmes for a specific and identifiable class of beneficiaries, namely medical, nursing, and allied healthcare students. Such activities cannot be equated with general public awareness campaigns or preventive health education envisaged under the notification. The fact that the trained professionals may, in the course of their future practice, contribute to improved health outcomes or awareness constitutes only an indirect or consequential benefit, which cannot be equated with direct public awareness activities - Further, the applicant does not satisfy the definition of "educational institution" under the notification to avail exemption under Entry No. 66. Accordingly, the services provided by the applicant are liable to GST at the rate of 18% under Commercial Training and Coaching Services – Ordered accordingly - Exemption under Entry 1 of Notification No. 12/2017-Central Tax (Rate) - Whether the BCLS course offered by the Applicant to students other than medical students qualifies as "charitable activities" – HELD - The activity does not qualify as "charitable activities" under the notification as it involves structured professional training and skill development for a specific class of beneficiaries (students), rather than dissemination of general public awareness. The Applicant also does not satisfy the definition of "educational institution" under the notification to avail exemption under Entry 66. Accordingly, the BCLS course offered to students other than medical students is liable to GST at 18%.

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