2026-VIL-123-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR - Exemption for services under National Mental Health Mission – Applicant is a Charitable Trust providing training and awareness activities related to mental health and trauma counselling to physically and mentally abused persons through work orders issued by Government Health Departments - Whether services qualify for exemption as charitable activities – HELD - The services provided by an entity registered under Section 12AB of the Income Tax Act by way of advancement of educational programmes or skill development relating to physically or mentally abused and traumatized persons fall within the definition of charitable activities under Entry No. 1 of Notification No. 12/2017-CT(Rate). The applicant providing mental health awareness, educational lectures, and training to community health workers under the National Mental Health Programme through a Government nodal agency satisfies the requirement of being registered under Section 12AB and the services constitute advancement of educational programmes relating to mentally traumatized persons. Therefore, the services are exempt from GST under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate), provided the applicant maintains valid registration under Section 12AB of the Income Tax Act – Ordered accordingly - GST Exemption for Self-Defence Training Services – Applicant providing self-defence training to women and girl students pursuant to work orders issued by police authorities under Suraksha Setu Programme and by education department for government schools - Whether services qualify for exemption under Entry No. 72 of Central Tax Notification – HELD - The services provided to State Government, State Government departments and State Government-run institutions under any training programme for which seventy-five percent or more of the total expenditure is borne by the State Government fall within Entry No. 72 of Notification No. 12/2017-Central Tax (Rate). The applicant providing self-defence training including judo, karate and basic defence tactics to female students through work orders issued by various police departments under the Suraksha Setu initiative and by district project offices of the education department, with full funding by the respective government agencies, qualifies for exemption as the services are provided to State Government and State Government-run institutions with one hundred percent cost borne by the government. Therefore, the services are exempt from GST under Entry No. 72 of Notification No. 12/2017-Central Tax (Rate) - Exemption for Training Services under Prime Minister Vishwakarma Scheme - Entity providing artisan mobilization and basic training for goldsmiths pursuant to work order issued by a government institute as implementing agency under a Central Government scheme - Whether services qualify for exemption under Entry No. 72 of Central Tax Notification – HELD - The Prime Minister Vishwakarma Scheme is a central sector scheme fully funded by the Government of India providing holistic support to artisans and craftspeople across eighteen designated trades. Services provided under this centrally-funded scheme by an entity designated as an agency for conducting artisan mobilization and training fall within Entry No. 72 of Notification No. 12/2017-Central Tax (Rate) as the services are provided to a government agency implementing a Central Government training programme for which hundred percent of the expenditure is borne by the Central Government. Therefore, services provided for training goldsmiths under the Prime Minister Vishwakarma Scheme are exempt from GST under Entry No. 72 of Notification No. 12/2017-Central Tax (Rate) - Exemption for Vocational Training Services - Entity providing vocational training including taekwondo and tailoring to girl students through work order issued by a government residential school scheme - Whether services qualify for exemption under Entry No. 72 of Central Tax Notification – HELD - The Kasturba Gandhi Balika Vidyalaya scheme established by the Government of India comprises residential schools operated with Government support for providing education and vocational training to girls from disadvantaged sections. Services provided to such Government-run schools for vocational training of students fall within Entry No. 72 of Notification No. 12/2017-Central Tax (Rate) as the services are provided to a government-run institution with expenditure borne by the Government - The services provided for vocational training at Kasturba Gandhi Balika Vidyalayas are exempt from GST under Entry No. 72 of Notification No. 12/2017-Central Tax (Rate) - Exemption for Yoga Camp Services - Whether services qualify for exemption as charitable activities – HELD - The services by an entity registered under Section 12AB of the Income Tax Act by way of advancement of spirituality or yoga constitute charitable activities under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate). Yoga camps conducted by the applicant, as an entity registered under Section 12AB, fall within the definition of charitable activities relating to advancement of spirituality or yoga. Therefore, services provided by way of conducting yoga camps are exempt from GST under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate), provided the applicant maintains valid registration under Section 12AB of the Income Tax Act - Exemption for De-addiction Seminars and Sanitation Training - Whether services qualify for exemption as charitable activities relating to preventive health – HELD - The preventive health encompasses proactive measures and public awareness aimed at preventing disease manifestation through provision of information on health risks and measures to reduce them. Conducting seminars for de-addiction providing information on health risks of tobacco and drug consumption and conducting training for cleaning and sanitation preventing disease transmission constitute public awareness of preventive health, which falls within the definition of charitable activities under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate). The applicant registered under Section 12AB providing such services qualifies for exemption. Therefore, services comprising conducting seminars for de-addiction from tobacco and drugs and conducting training for cleaning and sanitation are exempt from GST under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate), provided the applicant maintains valid registration under Section 12AB of the Income Tax Act - Exemption for Blood Donation Camp Services – Applicant conducting blood donation camps including mini health check-ups and blood screening - Whether services qualify for exemption as charitable activities relating to preventive health – HELD - The primary purpose of blood donation camps is to collect blood supply for medical emergencies and clinical use, with pathological examination conducted to prevent transmission of infections to recipients as per national blood transfusion guidelines and mini health check-ups conducted as ancillary safety protocols to protect donors. These ancillary check-ups cannot be stretched to constitute preventive health as defined under charitable activities, which encompasses proactive measures to prevent disease manifestation. Blood donation camps serve the purpose of blood collection and transfusion services rather than prevention of disease. Therefore, services comprising organization of blood donation camps do not fall within the ambit of charitable activities and are not exempt from GST under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate) - Exemption for Road Safety Training Services - Whether services qualify for exemption as charitable activities relating to preventive health – HELD - The preventive health encompasses taking proactive measures, screenings and check-ups to prevent diseases and health conditions through disease prevention methodologies. Road safety traini
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