The applicant, M/s Isha Foundation, is a Public Charitable Trust established by Sadhguru in 1992. The trust has exemptions under section 12AB and 80G of the Income Tax Act and aims to promote education, yoga, meditation, and charitable endeavors. The applicant sought to operate Isha Samskriti, a residential school in Karnataka, following a gurukul-style educational system to provide traditional Indian education, focusing on physical, mental, and energetic growth.

Although the school wouldn’t issue education certificates, students could opt for the National Open School examination at 10th and 12th grade levels. The applicant believed their education falls under Entry No. 57 of Notification No. 9/2017-Integrated Tax (Rate) dated 28th June 2017 and sought an advance ruling on its exemption status.

The bench reviewed the conditions for exemption under the mentioned notification. The service provider must be registered under section 12AA or 12AB of the Income-tax Act, and the services provided should be categorized as ‘charitable activities.’

The applicant met the first condition but did not qualify for the second. The trust deed’s objectives lacked specific mentions of activities related to the advancement of religion, spirituality, or yoga, leading the bench to conclude that Isha Samskriti’s services did not qualify as ‘charitable activities’ per the notification.

Additionally, the applicant’s curriculum did not fit the definition of an “educational institution” as per Notification No. 9/2017-Integrated Tax (Rate), thus not eligible for exemption under Entry No. 69 of the same notification.

As a result, the education provided by the applicant was not exempt under the mentioned notifications, and no other exemption applied to the service provided by Isha Foundation through ISHA Samskriti.