In re Sanskar Foundation (GST AAR Gujarat)
The Gujarat Authority for Advance Ruling (AAR) examined multiple questions raised by a charitable trust registered under the Bombay Public Charitable Trust Act, 1950 and under Section 12AB of the Income-tax Act, 1961 regarding GST exemption on various training programmes, seminars, yoga camps and welfare activities conducted under government schemes and work orders. The applicant sought clarification on the applicability of exemption entries underNotification No. 12/2017- Central Tax (Rate), particularly Entries 1, 54, 66, 69, 71 and 72.
The AAR observed that exemption claims had to be examined separately for each activity based on the relevant notification entry and the supporting documents furnished. It noted that the applicant had produced work orders for certain activities but had not submitted sufficient documentation for others, making it impossible to determine eligibility in those cases.
Regarding training for development of women under the Deen Dayal Upadhyaya Grameen Kaushalya Yojana, the Authority held that Entry 71 applies only to training providers functioning as Project Implementation Agencies. Since the applicant admitted that it was not registered as a Project Implementation Agency, the exemption under Entry 71 was denied. Similarly, no ruling was given on vocational training, computer training or ITI training under Entries 66, 69 or 72 because the applicant did not establish that it satisfied the prescribed conditions and had not produced the relevant work orders.
