In re The Coimbatore Branch of Indian Medical Association (GST AAR Tamilnadu)
The present matter concerns an application for advance ruling filed by the Coimbatore branch of the Indian Medical Association, which is engaged in conducting free medical health camps for underprivileged communities and organizing educational seminars and workshops for its member doctors. The applicant sought clarity on the applicability of GST to its activities, particularly in light of exemptions available for healthcare services under Notification No. 12/2017-Central Tax (Rate).
The key questions raised were: whether the activities of the association qualify as “business” under Section 2(17)(e) of the CGST Act, 2017; whether such activities constitute “supply” under Section 7(1)(aa) despite the principle of mutuality; and whether member subscription fees are taxable under GST.
The Authority examined the nature of activities carried out by the applicant, which include collection of subscription from members, conducting seminars and workshops for doctors, organizing free medical camps, and providing other services such as renting of immovable property. It was observed that Section 2(17)(e) explicitly includes the provision of facilities or benefits by a club, association, or society to its members for a subscription or consideration as a “business” activity. Accordingly, the Authority held that activities involving collection of subscription and provision of services to members, as well as organizing educational seminars and workshops for members, qualify as “business” under the said provision.
