Home-based nursing and physiotherapy qualify as exempt healthcare services under GST when provided by a clinical establishment.

Health-care services provided at patients' residences by qualified nurses, physiotherapists and other technically trained personnel were treated as exempt healthcare services under Serial No. 74 of Notification No. 12/2017-Central Tax (Rate). The ruling applied the definition of healthcare services as diagnosis, treatment or care for illness, injury, deformity, abnormality or pregnancy, and found that home-based nursing and supporting medical care fell within that scope. It also held that the provider functioned as a clinical establishment. The services were therefore not taxable under GST.

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Issues: Whether health-care services provided to patients at their residence by qualified nurses and other technically qualified persons are taxable under GST or exempt as healthcare services.

Analysis: The exemption under Serial No. 74 of Notification No. 12/2017-Central Tax (Rate) covers healthcare services provided by a clinical establishment, an authorised medical practitioner or paramedics. Healthcare services include diagnosis, treatment or care for illness, injury, deformity, abnormality or pregnancy. The applicant's services consisted of nursing care, physiotherapy and other supporting medical care rendered at patients' homes through qualified personnel. Such services fall within the scope of healthcare services. The applicant also answered the description of a clinical establishment, since it provided care for illness through an institution registered as a private paramedical institution and functioning as an establishment offering care services.

Conclusion: The services are exempt from GST under Serial No. 74 of Notification No. 12/2017-Central Tax (Rate), and are not taxable.

Ratio Decidendi: Services rendered for the care of illness by qualified healthcare personnel at patients' residences qualify as healthcare services when provided by a clinical establishment, and are exempt from GST under the relevant exemption entry.

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