In re Jeeva Raksha Trust (GST AAR Karnataka)
The Authority for Advance Ruling, Karnataka, examined the GST liability on fees received by a charitable trust conducting emergency care and life support courses, including c-ECLS, ENLS, and BCLS, for students of medical, nursing, and allied health institutions, as well as for the general public. The applicant, registered under Section 12AA of the Income Tax Act, claimed exemption under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate), contending that its activities constituted “charitable activities” in the nature of public awareness of preventive health.
The Authority first confirmed that the applicant satisfied the condition of being registered under Section 12AA. However, it examined whether the services qualified as “charitable activities” as defined under paragraph 2(r) of the notification. It observed that the definition is restrictive and limited to specified activities such as public awareness of preventive health directed at the general public.
The Authority analysed the nature of the courses and found that they were structured, specialised training programmes designed to impart clinical and emergency response skills to a defined group of beneficiaries, namely students and healthcare professionals affiliated with specific institutions. These courses were mandatory academic requirements and were conducted under institutional arrangements, with the applicant receiving a share of fees for training support and quality control functions.
