In re The Mining Geological And Metallargical Institute of India (GST AAR West Bengal)
The Mining, Geological & Metallurgical Institute of India (MGMI), a professional non-profit association incorporated as a company limited by guarantee under the Companies Act, 1882 and governed under Section 8 of the Companies Act, 2013, sought an advance ruling from the Authority for Advance Ruling (AAR), West Bengal, on the applicability of GST on its sponsorship services. The applicant promotes mining, geology, and metallurgy in India through conferences, exhibitions, seminars, technical lectures, and publications. Its activities include student outreach, industry networking, and professional development programs. MGMI derives receipts from membership fees, journal sales, sponsorships, and delegate registration fees, all of which are applied solely for its objectives, office upkeep, and administrative expenses. The institute operates on a no-profit basis, has never declared dividends, and has no beneficial shareholders. MGMI is registered under Section 12A/12AB of the Income Tax Act and under the GST Act as a “Society/Club/Trust/AOP.”
The applicant raised three questions under Section 97(1) of the GST Act regarding whether: (i) it qualifies as a “body corporate” under the CGST, IGST, and SGST Acts; (ii) sponsorship services rendered by it should be treated as services by a “body corporate” under Notification No. 10/2017–IGST and No. 13/2017–CGST as amended by Notification No. 07/2025; and (iii) GST on sponsorship services is payable under reverse charge mechanism (RCM) or forward charge mechanism (FCM) following the 2025 notification amendments.
