GST Exemption Status for Charitable Trust Training and Awareness Services
The Gujarat Authority for Advance Ruling clarified which charitable and government-funded training services qualify for GST exemptions.
- Ruling
- GUJ/GAAR/R/2026/22 dated 24.06.2026
- Dated
- 24 Jun 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
- Mental health and yoga services are exempt if the trust holds 12AB registration.
- Government-funded training programs are exempt if the government covers 75% of costs.
- Blood donation and road safety training do not qualify for charitable GST exemptions.
In short
A charitable trust asked the Gujarat Authority for Advance Ruling (AAR) whether its various training, awareness, and health-related services are exempt from Goods and Services Tax (GST). The authority reviewed several activities, including mental health missions, self-defence training, and vocational programs, to determine if they fall under specific tax exemption notifications.
What has changed
How it worked before
Charitable trusts often assumed that most activities performed for public welfare or under government contracts were automatically exempt from GST.
What has changed
The authority confirmed that exemptions depend strictly on the specific nature of the service and funding source. It ruled that while many training programs are exempt, activities like blood donation and road safety training do not meet the legal definition of 'preventive health' and are therefore taxable.
Who this affects
Charitable trusts, NGOs, and non-profit organizations providing training or awareness services under government contracts.
An example
A charitable trust provides road safety training under a local government contract. They might assume this is a charitable activity and therefore exempt from GST. Based on this ruling, the trust should realize that road safety training is not considered 'preventive health' and must likely charge GST on these services.
What you should do
Review your specific service agreements against the criteria in Notification No. 12/2017-Central Tax (Rate). Remember that an Advance Ruling only binds the specific business that requested it and their local tax office; it is not a universal law for all trusts.
If you do nothing
If you incorrectly assume your services are exempt, you may fail to collect and pay the required GST. This can lead to tax demands, interest charges, and penalties when your records are audited. A tax officer is not required to follow this ruling if your specific facts differ from those presented by the applicant.
The terms explained
- Advance Ruling
- A formal decision provided by tax authorities to a specific business regarding how tax laws apply to their particular situation.
- 12AB Registration
- A registration under the Income Tax Act that allows charitable trusts to claim tax exemptions on their income.
- Preventive Health
- Medical services specifically aimed at preventing the occurrence or spread of diseases, which qualifies for certain tax benefits.
The ruling in detail
Authority for Advance Ruling
M/s. Sanskar Foundation
GUJ/GAAR/R/2026/22 dated 24.06.2026 · Gujarat
Questions before the authority
- Whether the services provided by the applicant by way of providing services under National Mental Health Mission is exempt under GST under Sr No 1 of Notification No 12/2017- Central Tax (Rate)?
- Whether the services provided by the applicant by way of providing services under National Mental Health Mission is exempt under GST under Sr No 72 of Notification No 12/2017- Central Tax (Rate)?
- Whether the services provided by the applicant by way of providing self-defence training for women (i) as per the order of the Gujarat Police; (ii) self defence programme under Surakhsha Setu Programme by Gujarat Police (iii) Self Defence training for females by State Project Office implemented through Education Department, Govt of Gujarat is exempt under GST under Sr No 72 of Notification No 12/2017- Central Tax (Rate)?
- Whether the services of training to Goldsmiths provided to Gujarat Matikaam Kalakari and Rural Technology Institute (or the institutes Conducting training and seminars for Prime Minister Vishwakarma conducted by Government and Semi Government institutions) is exempt under GST under Sr No 72 of Notification No 12/2017-Central Tax (Rate)?
- Whether the services provided by the applicant by way of providing vocational training at Kasturba Gandhi Balika Vidhyalay is exempt under GST under Sr No 72 of Notification No 12/2017-Central Tax (Rate)?
- Whether conducting seminar for development of women is exempt under Sr No 71 or under Sr No 72 of Notification No 12/2017-Central Tax (Rate))?
- Whether (a) Providing vocational training and (b) Providing computer or ITI Training is covered under No 69 or under Sr No 66 or under Sr No 72 of Notification No 12/2017- Central Tax (Rate))?
- Whether the services provided by the applicant by way of yoga camp is exempt under GST under Sr No 1 of Notification No 12/2017- Central Tax (Rate)?
- Whether the services provided by way of providing training to agriculturist is exempt under GST under Sr No 54 of Notification No 12/2017-Central Tax (Rate)?
- Whether conducting seminar for (a) deaddiction (De toxification) of tobacco and drugs; (b) Conducting training for cleaning and sanitation (c) blood donation camp (d) Road safety training is exempt under Sr No 1 of Notification No 12/2017-Central Tax (Rate))?
Facts
The applicant is a charitable trust registered under the Bombay Public Charitable Trust Act and Section 12AB of the Income Tax Act. They provide various vocational, self-defence, and awareness training programmes under work orders issued by various State and Central Government departments. The applicant seeks an advance ruling on the GST exemption status of these diverse service activities.
Ruling
| Question | What the authority ruled |
|---|---|
| Q1: National Mental Health Mission (Sr No 1) | Yes Subject to valid 12AB registration |
| Q2: National Mental Health Mission (Sr No 72) | Not answered In view of answer to Q1 |
| Q3: Self-defence training for women | Yes Under Sr No 72 |
| Q4: Training to Goldsmiths/PM Vishwakarma | Yes Under Sr No 72 |
| Q5: Vocational training at Kasturba Gandhi Balika Vidhyalay | Yes Under Sr No 72 |
| Q6: Seminar for development of women | No For reasons mentioned in order |
| Q7: Vocational/Computer/ITI training | Not answered For reasons mentioned in order |
| Q8: Yoga camp | Yes Subject to valid 12AB registration |
| Q9: Training to agriculturist | Not answered For reasons mentioned in order |
| Q10: De-addiction, cleaning, blood donation, road safety | De-addiction and cleaning are exempt; blood donation and road safety are not De-addiction and cleaning exempt under Sr No 1 subject to valid 12AB registration |
The Authority ruled that services provided under the National Mental Health Mission and yoga camps are exempt under Sr. No. 1, subject to valid 12AB registration. Self-defence training, vocational training for Goldsmiths, and training at Kasturba Gandhi Balika Vidyalayas are exempt under Sr. No. 72. Seminars for de-addiction and training for cleaning and sanitation are exempt under Sr. No. 1, while blood donation camps and road safety training are not exempt.
Reasoning
The Authority relied on Notification No. 12/2017-Central Tax (Rate). It held that charitable activities under Sr. No. 1 require valid 12AB registration. Services provided to the Government under training programmes where 75% or more of the expenditure is borne by the Government are exempt under Sr. No. 72. The Authority rejected the applicant's claim that blood donation and road safety training constitute preventive health under charitable activities, stating these do not meet the definition of disease prevention.
Provisions relied on
- Notification No. 12/2017-Central Tax (Rate)
- Section 12AB of the Income Tax Act, 1961
- Section 97(2) of the CGST/GGST Act, 2017
For the practitioner
This ruling clarifies that charitable trusts must maintain valid 12AB registration to claim exemptions under Sr. No. 1. It confirms that training services fully funded by government departments are generally exempt under Sr. No. 72. However, it strictly limits the scope of 'preventive health' under charitable activities, excluding activities like blood donation and road safety training.
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/1-sanskar_foundation_final_scan.pdf
Legibility of the scan, as read: high.
Prepared 11-10-2026.
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