In a significant ruling, the Supreme Court delivered a setback to the Patanjali Yogpeeth Trust, affirming an earlier decision by an appellate tribunal that held the Trust liable to pay service tax for its Yoga camps. The ruling encompasses both residential and non-residential camps where an entry fee is charged.The apex court, comprising Justices Abhay S Oka and Ujjal Bhuyan, declined to intervene in the verdict issued by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) on October 5, 2023, from the Allahabad bench. The Tribunals decision categorised the Trusts Yoga camps as falling under health and fitness service and therefore subject to service tax.In its dismissal of the Trusts appeal, the bench stated, The tribunal has rightly held that Yoga in camps for a fee is a service. We do not find any reason to interfere with the impugned order. The appeal is dismissed.Patanjali Yoga CampsThe CESTATs order emphasized that the Patanjali Yogpeeth Trust, overseen by Yoga guru Ramdev and Acharya Balkrishna, conducts Yoga training sessions at various camps, charging fees from participants under the guise of donations. The Tribunal noted the Commissioners demand for approximately ₹ 4.5 crore in service tax, covering the period from October 2006 to March 2011, along with penalties and interest.The Trust argued that its services were oriented towards curing ailments and hence fell outside the taxable domain of health and fitness service. However, the appellate tribunals scrutiny found no concrete evidence supporting this claim.Disguised Entry FeesThe Tribunals analysis pointed out that the Trust, under the pretext of donations, collected entry fees through ticketing systems with varying privileges. These fees were ostensibly for access to the camps where Ramdev delivered Yoga and Meditation instructions, making them eligible for service tax under the relevant tax provisions.The ruling underscores the meticulous assessment of service categorization and taxation, aligning with regulatory standards for entities offering health and fitness services, even in charitable or wellness contexts.
