Healthcare Diagnostic Services Exempt from CGST & KGST under Notification No. 12/2017

The Authority ruled that the diagnostic services provided by the healthcare service provider to hospitals are exempt from CGST and KGST under entry no. 74 of Notification No. 12/2017. The ruling confirmed that the services qualify for exemption as healthcare services by a clinical establishment, as per the relevant provisions of the tax acts.

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Issues:
1. Whether the applicant, a healthcare service provider, is exempt from tax or notRs.

Analysis:
The applicant, an unregistered Private Limited Company, filed for an Advance Ruling seeking exemption from tax as a healthcare service provider. The applicant operates on a PPP model with government hospitals for diagnostic services. They bear all related expenses, receive bills from vendors with different GST slabs, and pay expenses including GST without claiming ITC. The applicant does not engage in services under reverse charge mechanism. The applicant listed services provided to various hospitals and detailed their billing process based on government schemes.

Findings & Discussion:
The Authority examined the applicant's transaction and determined that the services provided were to the contractee hospitals, not directly to patients. The contractee is deemed the recipient of services as per the CGST Act. The applicant sets up infrastructure for diagnostic services within hospital premises, falling under the definition of "healthcare services" as per Notification No. 12/2017. The term "clinical establishment" includes institutions offering diagnostic services, thus covering the applicant's services.

The Notification No. 12/2017 exempts healthcare services by a clinical establishment from GST. The applicant's diagnostic services fall under this exemption as a clinical establishment. The ruling states that the diagnostic services provided by the applicant to hospitals are exempt from CGST and KGST under entry no. 74 of Notification No. 12/2017. The ruling confirms that the applicant's services are covered under the exemption for healthcare services by a clinical establishment.

In conclusion, the Authority ruled that the diagnostic services provided by the applicant to hospitals are exempt from CGST and KGST under entry no. 74 of Notification No. 12/2017. The ruling affirms that the applicant's services qualify for exemption as per the relevant provisions of the tax acts.

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