Case Of: Sadbhavana Seva Foundation
Issued By: Gujarat AAR
Order No: GUJ/GAAR/R/2025/64
Date: 23rd Dec 2025
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The applicant, Sadbhavana Seva Foundation, is a charitable organisation registered under Sections 12AA/12AB of the Income Tax Act and is a sister concern of Manav Charitable Trust, engaged in activities aligned with environmental protection and social welfare.
The applicant was selected by the Gujarat Forest Department under the “Harit Van Path Yojana” for the year 2025–26, a large-scale afforestation initiative aimed at increasing tree cover and ecological balance across the State.
Under the project, valued at approximately ₹113.65 crore, the applicant was entrusted with the plantation and maintenance of over 7.6 lakh trees across non-forest areas such as roadsides, barren land, vacant plots, private land, and other accessible locations.
The applicant sought an advance ruling on whether plantation and maintenance of trees undertaken as part of its charitable objectives would qualify as an exempt supply under Entry No. 1 of Notification No. 12/2017–Central Tax (Rate), being activities relating to preservation of the environment.
The Gujarat AAR examined the objectives of the Harit Van Path Yojana in light of the National Forest Policy, which expressly promotes expansion of green cover through plantation along roads, canals, rivers, and unutilised lands, including those under private or institutional ownership.
It was observed that plantation and maintenance of trees in non-forest areas directly contribute to environmental preservation by preventing soil erosion, improving microclimate, combating desertification, and enhancing ecological sustainability.
On perusal of the applicant’s Memorandum of Association, the Authority noted that environmental protection and development of a clean environment through tree plantation formed an integral part of its stated charitable purposes.
Accordingly, the Gujarat AAR held that the applicant’s activities squarely fall under “preservation of the environment” as covered by Entry No. 1 of Notification No. 12/2017–CTR and are therefore exempt from GST, relying also on the earlier AAR ruling in Vikas Centre for Development (2023) where mangrove plantation was similarly held to be exempt.