Facts of the case: In this case, the Applicant was a charitable trust registered under the Bombay Public Trusts Act, 1950 and holding registration under Section 12AB of the Income-tax Act, 1961, was engaged in conducting a wide range of public welfare, vocational, educational and health-related programmes under assignments received from various Central and State Government departments and Government-controlled institutions. These activities included implementation of the National Mental Health Programme, self-defence training for women under Gujarat Police and the Suraksha Setu Programme, vocational training in Kasturba Gandhi Balika Vidyalayas, artisan training under the Pradhan Mantri Vishwakarma Scheme, seminars for women’s empowerment, yoga camps, agricultural training, computer and ITI training, de-addiction awareness programmes, sanitation awareness, blood donation camps and road safety training.

Uncertain about the GST implications of these diverse services, the applicant sought an advance ruling on whether the various activities qualified for exemption under different entries of Notification No. 12/2017-Central Tax (Rate), particularly Entries 1, 54, 66, 69, 71 and 72.

The Authority examined the nature of each activity, the statutory conditions attached to the respective exemption entries, the applicant’s charitable registration, and the supporting work orders and documents furnished before determining the eligibility of each service for exemption.

Issue: Whether the various training programmes, awareness campaigns, vocational courses and public welfare activities undertaken by the applicant for Government departments, Government-funded institutions and public beneficiaries qualified for GST exemption under the respective entries of Notification No. 12/2017-Central Tax (Rate). Whether registration under Section 12AB of the Income-tax Act, by itself, entitled the applicant to exemption, whether Government-funded training programmes satisfied the conditions of Entry 72, whether services constituted “charitable activities” under Entry 1, and whether activities such as blood donation camps and road safety training could be regarded as preventive health services eligible for exemption.

Held That: The Gujarat Authority for Advance Ruling held that exemption under Notification No. 12/2017-Central Tax (Rate) must be examined independently for each activity with strict reference to the conditions prescribed under the relevant exemption entry. The Authority ruled that services rendered under the National Mental Health Programme, yoga camps, de-addiction awareness programmes, and cleaning and sanitation awareness programmes qualified as charitable activities under Entry 1, subject to the applicant possessing a valid registration under Section 12AB of the Income-tax Act.

It further held that self-defence training conducted under Gujarat Police, the Suraksha Setu Programme, Government schools, vocational training at Kasturba Gandhi Balika Vidyalayas, and artisan training under the Pradhan Mantri Vishwakarma Scheme were exempt under Entry 72 since the services were supplied under Government training programmes substantially funded by the Central or State Government.

However, exemption was denied for training under the Deen Dayal Upadhyaya Grameen Kaushalya Yojana because the applicant was not a recognised Project Implementation Agency as required under Entry 71. The Authority also declined to rule on vocational training, computer training, ITI training and agricultural extension services due to the absence of supporting work orders and sufficient factual material. Additionally, it held that blood donation camps and road safety training did not fall within the statutory definition of “charitable activities” or “preventive health” under Entry 1 and, therefore, were not eligible for GST exemption.

Case Name: In re. M/s SANSKAR FOUNDATION dated 24.06.2026

To read the complete judgement 2026 Taxo.online 1758