GST on Specialized Medical Training Courses by Charitable Trusts
The Karnataka Authority for Advance Ruling decided that specialized medical training provided by a trust is taxable at 18% GST.
- Ruling
- Order No. KAR.ADRG 18/2026 dated 16.03.2026
- Dated
- 16 Mar 2026
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- JeevaRaksha Trust asked if their medical training courses were exempt from GST.
- The Authority ruled these are commercial training services, not charitable activities.
- All fees received for these courses and renewals are subject to 18% GST.
In short
The company asked if their emergency care training courses for medical and nursing students qualified for a GST exemption as a charitable activity. The tax authority examined whether these courses, which are mandatory for students, could be treated as education or charity.
What has changed
How it worked before
Many charitable trusts assumed that providing training for medical students or public health programs was exempt from GST under the charitable activity category.
What has changed
The authority ruled that these services are classified as commercial training and coaching. Because the trust is not an educational institution and the training is specialized professional instruction rather than a public awareness program, it does not qualify for tax relief.
Who this affects
Charitable trusts or private organizations that provide specialized training or coaching services to students in medical, nursing, or other professional colleges.
An example
Imagine a private trust that provides mandatory surgical technique workshops to medical students at various universities. They might assume these are exempt because they support medical education. Based on this ruling, the trust would likely be required to charge 18% GST on the fees they receive for these workshops.
What you should do
If you provide similar training, you should review your tax liability with a professional. Remember that an Advance Ruling only binds the specific business that asked for it and their local tax office; it is not a general law that applies to your business automatically.
If you do nothing
If you assume your services are exempt and stop collecting GST, you risk a tax demand for the unpaid tax plus interest and penalties. A tax officer may disagree with your interpretation during an audit, leading to significant financial liability for your organization.
The terms explained
- Commercial Training and Coaching Services
- A category of services that includes private instruction or training provided for a fee, which is generally subject to GST.
- Charitable Activity
- Specific activities defined by tax law that are exempt from GST, such as public awareness programs or certain religious or charitable functions.
- Advance Ruling
- A formal decision by tax authorities on a specific question asked by a business, which clarifies how tax laws apply to that specific situation.
The ruling in detail
Authority for Advance Ruling
M/s JeevaRaksha Trust
Order No. KAR.ADRG 18/2026 dated 16.03.2026 · Karnataka
Questions before the authority
- Whether the applicant is liable to pay GST on the share of fees received from colleges in respect of the C-ECLS (Comprehensive Emergency Care and Life Support) course offered to the students of MBBS in RGUHS affiliated medical colleges?
- Whether the applicant is liable to pay GST on the share of fees received from colleges in respect of the ENLS (Emergency Nursing Care and Life Support) course offered to the students of Nursing in RGUHS affiliated nursing colleges?
- Whether the applicant is liable to pay GST on the share of fees received from colleges in respect of the BCLS (Basic Care and Life Support) course offered to the students in RGUHS affiliated medical colleges?
- Whether the applicant is liable to pay GST on the fees collected from students in general (other than medical students) in respect of the BCLS Course?
- Whether the applicant is liable to pay GST on the fees collected/share of fees received from colleges in respect of renewal of certificate for c-ECLS/ENLS/BCLS course?
Facts
The applicant is a charitable trust that provides specialized emergency care and life support training courses (C-ECLS, ENLS, and BCLS) to students in medical, nursing, and allied health colleges affiliated with RGUHS. These courses are mandatory for the students to complete their degrees. The fees paid by students are apportioned between the colleges, the university, and the applicant, with the applicant receiving a share for providing training support and quality control.
Ruling
| Question | What the authority ruled |
|---|---|
| GST liability on share of fees for C-ECLS, ENLS, and BCLS courses | Liable to GST Not eligible for exemption under Entry No. 01 of Notification No. 12/2017-Central Tax (Rate) |
| GST liability on fees for BCLS course for non-medical students | Liable to GST Not eligible for exemption under Entry No. 01 or Entry No. 66 of Notification No. 12/2017-Central Tax (Rate) |
| GST liability on fees for renewal of certificates | Liable to GST Classifiable under SAC 999293 at 18% rate |
The Authority ruled that the services provided by the applicant do not qualify as charitable activities under the relevant notification and are therefore not exempt from GST. The activities are classified as commercial training and coaching services. Consequently, the applicant is liable to pay GST at the rate of 18% on all fees received for these courses and their renewals.
Reasoning
The Authority determined that the applicant's services do not fall under the definition of charitable activities in paragraph 2(r) of Notification No. 12/2017-Central Tax (Rate) because they are not public awareness programs but rather **specialized professional training** for a limited class of beneficiaries. Furthermore, the applicant does not qualify as an educational institution under paragraph 2(y) of the same notification, as the courses are not part of a curriculum leading to a recognized qualification. The services are correctly classified under **SAC 999293 - Commercial Training and Coaching Services**, which is taxable at 18%.
Provisions relied on
- Section 98(4) of the CGST Act, 2017
- Section 97 of the CGST Act, 2017
- Entry No. 1 of Notification No. 12/2017-Central Tax (Rate)
- Entry No. 66 of Notification No. 12/2017-Central Tax (Rate)
- Paragraph 2(r) of Notification No. 12/2017-Central Tax (Rate)
- Paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate)
- Serial No. 30 of Notification No. 11/2017-Central Tax (Rate)
For the practitioner
This ruling clarifies that specialized training provided to students under institutional arrangements does not qualify for the charitable activity exemption, even if the training has a public health objective. It reinforces that **tax exemptions must be construed strictly** and cannot be expanded based on the broader societal benefits of the activity. Practitioners should note that mandatory academic training provided by third-party trusts is generally taxable as commercial coaching.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/5-aar-jeevaraksha_trust-compressed.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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