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Issues: (i) Whether the share of fees received from affiliated colleges in respect of c-ECLS, ENLS and BCLS courses, including renewal of certificates, qualifies as charitable activities exempt under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017. (ii) Whether the BCLS course offered to students other than medical students is exempt under Entry No. 1 or Entry No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017. (iii) Whether the services provided are classifiable as commercial training and coaching and liable to GST.
Issue (i): Whether the share of fees received from affiliated colleges in respect of c-ECLS, ENLS and BCLS courses, including renewal of certificates, qualifies as charitable activities exempt under Entry No. 1 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
Analysis: Entry No. 1 grants exemption only to services by an entity registered under Section 12AA or Section 12AB of the Income-tax Act, 1961 by way of charitable activities, and paragraph 2(r) confines charitable activities to the specified categories, including public health by way of public awareness of preventive health. The courses in question are specialised, structured training programmes delivered to a limited and identifiable class of beneficiaries in an academic setting, with evaluation, certification and renewal requirements. They do not disseminate awareness to the general public and their direct character is professional skill training rather than public awareness.
Conclusion: The courses and their renewal do not qualify as charitable activities and are not exempt under Entry No. 1. GST is payable on the share of fees received from affiliated colleges.
Issue (ii): Whether the BCLS course offered to students other than medical students is exempt under Entry No. 1 or Entry No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
Analysis: The BCLS course, even when offered to students other than medical students, remains a structured skill-based training programme and not public awareness of preventive health. For Entry No. 66, the applicant must first qualify as an educational institution within paragraph 2(y), which requires education up to higher secondary level, education as part of a curriculum for a qualification recognised by law, or an approved vocational education course. The applicant satisfies none of these conditions because the certificate issued is only a skill-development certification and not a recognised educational qualification.
Conclusion: The BCLS course for students other than medical students is not exempt under Entry No. 1 or Entry No. 66 and is liable to GST.
Issue (iii): Whether the services provided are classifiable as commercial training and coaching and liable to GST.
Analysis: The services consist of imparting specialised emergency care and life support skills to identified participants for consideration. Such activity falls within the scope of commercial training and coaching under SAC 999293. It does not fall within any exempt educational or charitable category.
Conclusion: The services are classifiable as commercial training and coaching under SAC 999293 and are liable to GST at 18%.
Final Conclusion: The requested exemption is unavailable, and the applicant's courses and certificate-renewal services remain taxable as commercial training and coaching services.
Ratio Decidendi: An exemption for charitable activities must be construed strictly, and specialised, institutional skill-training for identified beneficiaries does not amount to public awareness of preventive health or an educational institution service unless it squarely satisfies the notification's defined conditions.
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