Member Subscriptions and Seminars Taxable as Business | AAR

Case Details: The Coimbatore Branch of Indian Medical Association, In re - [2026] 185 taxmann.com 479 (AAR-TAMILNADU)

Judiciary and Counsel Details

• C. Thiyagarajan & B. Suseel Kumar, Member

Facts of the Case

The applicant sought an advance ruling on whether its activities of collecting subscription from members, conducting seminars, workshops, and providing related facilities would constitute ‘business’ and ‘supply’ under GST. It was submitted that although its primary objective included conducting health camps for economically weaker sections of society and organising educational programmes for medical professionals, such activities were carried out for mutual benefit and professional development, and therefore ought not to be treated as taxable supplies. It further contended that the principle of mutuality applied to member-related transactions and accordingly excluded such activities from GST levy. The matter was accordingly placed before the Authority for Advance Ruling (AAR).

AAR Held

The AAR held that under the Section 2(17)(e) of the CGST Act, the provision of facilities or benefits by an association to its members for subscription or other consideration constitutes ‘business’ and therefore the applicant’s activities fall within its ambit. It further held that under Section 7(1)(aa) of the CGST Act, read with its explanation deeming a body and its members as distinct persons notwithstanding any other law or judicial principle, transactions between an association and its members constitute ‘supply’ under GST. The Authority observed that collection of subscription and organisation of seminars and workshops for members clearly involved consideration and fell within the statutory definition of supply. It accordingly ruled that such activities are taxable under GST.

List of Cases Referred to

• Madras Gymkhana Club Employees Union v. Management of the Gymkhana Club 1967 taxmann.com 49 (SC) (para 2.2)
• Cricket Club of India Ltd. v. Bombay Labour Union [1969] 1968 taxmann.com 146 (SC) (para 2.2)
• Joint Commercial Tax Officer v. Young Men’s Indian Association 1970 taxmann.com 192 (SC) (para 2.2)
• Ranchi Club Ltd. v. Chief CCE & ST [2012] 22 taxmann.com 217/26 STR 401/36 STT 64 (Jharkhand) (para 2.2)
• Indian Medical Association v. UOI [2024] 164 taxmann.com 626/105 GST 445/88 GSTL 258 (Kerala) (para 5.5).