Applicant's Activities Not Exempt under Notification, Eligible for Input Tax Credit

The ruling determined that the activities of the applicant fell under SAC 998599, making them ineligible for exemption under Notification No. 9/2017-Integrated Tax (Rate). The applicant could claim input tax credit for inward supplies, subject to relevant provisions. Tax liability on outward services was set at 9% CGST and 9% KGST, with registration mandated under section 22 of the CGST Act due to intra-State service provision.

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Issues Involved:
1. Applicable SAC for the activities.
2. Applicability of exemption under Notification No. 9/2017-Integrated Tax (Rate) dated 28.06.2017.
3. Eligibility to avail input tax credit.
4. Tax liability on outward services and applicable rate.
5. Requirement for registration under the GST Act.

Issue-wise Detailed Analysis:

1. Applicable SAC for the Activities:
The activities undertaken by the applicant, M/s Vevaan Ventures, are classified under SAC 998599. This classification covers support services for research, which includes activities such as identifying research sites, onboarding research staff, purchasing necessary medical equipment, and managing the research process in India.

2. Applicability of Exemption under Notification No. 9/2017-Integrated Tax (Rate) dated 28.06.2017:
The applicant argued that their services qualify as "Healthcare Services" provided by a "Clinical Establishment" and should be exempt under Notification No. 9/2017-Integrated Tax (Rate). However, the authority concluded that the services provided by the applicant are not in connection with diagnosis, treatment, or care for illness but are support services for research. Therefore, these services do not qualify as "Healthcare Services" and are not exempt under the said notification.

3. Eligibility to Avail Input Tax Credit:
Since the services provided by the applicant are not exempt, the applicant is eligible to claim and avail input tax credit for the tax paid on inward supplies, subject to the provisions of section 16 of the CGST Act, 2017 and KGST Act, 2017.

4. Tax Liability on Outward Services and Applicable Rate:
The applicant's activities are covered under entry no. 23(ii) of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017. The services are liable to tax at the rate of 9% CGST and 9% KGST.

5. Requirement for Registration under the GST Act:
The applicant is involved in intra-State supply of services, as the location of the supplier and the place of supply is the same state. Therefore, the applicant is liable to register under section 22 of the CGST Act, 2017.

Ruling:
1. The activities undertaken by the applicant are covered under SAC 998599.
2. The exemption under Notification No. 9/2017-Integrated Tax (Rate) dated 28.06.2017 is not applicable to the applicant's transactions.
3. The applicant can avail input tax credit of tax paid on inward supplies, subject to section 16 of the CGST Act, 2017.
4. The applicant is liable to tax on outward supplies at the rate of 9% CGST and 9% KGST.
5. The applicant is required to register under section 22 of the CGST Act, 2017.

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