Eldercare and home-based medical support services are taxable where the provider is not a clinical establishment or authorised practitioner.

Eldercare and home-based medical support services supplied through membership packages and separate charges did not qualify for GST exemption as health care services because the exemption applies only when such services are provided by a clinical establishment, an authorised medical practitioner, or para-medics. The provider did not fall within any of those categories. The composite supply, comprising medical monitoring, home visits, emergency assistance, daily activity support, and logistics, was treated as human health and social care services under the rate notification and was therefore taxable at 18%.

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Issues: (i) Whether the eldercare and home-based medical support services provided to senior citizens qualified for exemption as health care services under the GST exemption notification; (ii) If not exempt, the applicable rate of tax on such services.

Issue (i): Whether the eldercare and home-based medical support services provided to senior citizens qualified for exemption as health care services under the GST exemption notification.

Analysis: The services comprised regular medical monitoring, home visits by medical professionals, assistance in medical emergencies, and several logistical and social support functions supplied under membership packages and separately charged items. Although some components could fall within the broad meaning of health care services, the exemption under Serial No. 74 of Notification No. 12/2017-Central Tax (Rate) applies only when such services are supplied by a clinical establishment, an authorised medical practitioner, or para-medics. The applicant did not fall within any of those categories.

Conclusion: The services did not qualify for exemption.

Issue (ii): If not exempt, the applicable rate of tax on such services.

Analysis: The overall supply was characterised as eldercare with human health and social care elements, including accompaniment, assistance with daily activities, medical support, and logistics. Such supply was held to fall under the relevant taxable entry for human health and social care services in the rate notification.

Conclusion: The services were liable to tax at 18%.

Final Conclusion: The ruling determines that the applicant's doorstep eldercare and associated support services are taxable and do not enjoy GST exemption.

Ratio Decidendi: Health care-related services are exempt only when supplied by a clinical establishment, an authorised medical practitioner, or para-medics, and a composite eldercare service provider outside those categories is taxable under the applicable rate entry.

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