Charitable health-awareness services by a section 12AA trust qualify as exempt supply under GST.

Activities undertaken by a public charitable trust registered under section 12AA, in partnership with UNICEF, relating to public awareness of preventive health were treated as a supply of services under GST. Because the exemption entry in Notification No. 12/2017-Central Tax (Rate) covers services by a section 12AA-registered entity by way of charitable activities, and the definition of charitable activities expressly includes public awareness of preventive health, the applicant's awareness work fell within that scope. The preventive-health awareness component was therefore exempt from GST under Sl. No. 1 of the notification read with paragraph 2(r)(i)(B).

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Issues: Whether the activities undertaken in partnership with UNICEF, relating to public awareness of preventive health, constituted a supply of services under GST and, if so, whether they were exempt under the relevant exemption notification.

Analysis: The applicant was a public charitable trust registered under section 12AA of the Income-tax Act, 1961. The relevant exemption entry in Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 covers services by an entity registered under section 12AA by way of charitable activities. The definition of charitable activities in paragraph 2(r)(i)(B) specifically includes public awareness of preventive health, family planning, or prevention of HIV infection. On a reading of the nature of the applicant's UNICEF-linked work, the activities relating to awareness of preventive health fell within that definition.

Conclusion: The activity relating to public awareness of preventive health amounted to supply of services and was exempt from GST under Sl. No. 1 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 read with paragraph 2(r)(i)(B).

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