Religious Institution Room Rentals: Taxable Thresholds & Exemptions

The Authority clarified that renting rooms and stalls for religious purposes by a religious institution could be taxable if charges exceed specified thresholds outlined in Notification 12/2017. Room rentals below Rs. 1,000 per day were deemed non-taxable, while stall rentals below Rs. 10,000 per month were exempt. The primary objective of advancing religion exempted the institution from tax liability unless thresholds were surpassed. Queries on supplying subsidized food, providing space without consideration, and acting as an intermediary for booking hotel rooms were withdrawn, resulting in no specific rulings on these matters.

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Issues:
1. Liability to pay tax on renting of temporary residential rooms and space for stalls for religious purposes.
2. Tax liability on renting rooms based on categories and charges.
3. Tax liability on renting space for stalls for religious purposes.
4. Tax liability on supplying food and beverages at subsidized rates.
5. Tax liability on providing space for registered persons without consideration.
6. Tax liability for acting as an intermediary for booking hotel rooms.

Analysis:
1. The applicant, a religious institution, sought clarification on the taxability of renting rooms and stalls for religious purposes. The Authority discussed relevant case laws, emphasizing that incidental transactions not constituting business activities are considered charitable. However, specific exemptions under Notification 12/2017 apply, making room rentals taxable if charges exceed Rs. 1,000 per day, and stall rentals taxable if charges exceed Rs. 10,000 per month.

2. The Authority ruled that room rentals below Rs. 1,000 per day are not taxable under Entry 13 of Notification 12/2017. The categorization of rooms based on facilities provided does not alter the tax liability if charges remain below the specified threshold.

3. Renting space for stalls for religious programs is taxable only if the monthly rent exceeds Rs. 10,000. The predominant objective being the advancement of religion exempts the applicant from tax liability unless the specified thresholds are breached.

4. The applicant's query regarding supplying food and beverages at subsidized rates was withdrawn as the services were not provided. Hence, the Authority did not provide a ruling on this issue.

5. Similarly, the question concerning providing space for registered persons without consideration for supplying food and beverages was withdrawn as the service was not rendered, leading to no ruling on this matter.

6. The Authority did not rule on the tax liability for acting as an intermediary for booking hotel rooms for pilgrims from outside as the applicant withdrew questions related to this service. Therefore, no specific ruling was provided on this issue.

This detailed analysis of the judgment clarifies the tax implications of renting rooms and stalls for religious activities as per the provisions of the GST Act and relevant notifications.

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