Advance ruling maintainability turns on full disclosure of supply details and documents before claiming a health care exemption.

An advance ruling application was found not maintainable because the applicant did not furnish enough particulars and supporting documents to establish the exact nature of the supply under the "Diamond Plan" or verify that it fell within the health care services exemption in Notification No. 12/2017-Central Tax (Rate). The bundled medical and allied services, together with unspecified tie-up arrangements with other hospitals, left the tax treatment unascertainable. The ruling emphasizes that an advance ruling may be refused where the factual record is insufficient to determine the nature of the supply and its eligibility for exemption.

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Issues: Whether the application seeking advance ruling on exemption for the lump-sum amount received under the "Diamond Plan" was maintainable.

Analysis: The exemption claimed under serial no. 74 of Notification No. 12/2017-Central Tax (Rate) applies to health care services by a clinical establishment, an authorised medical practitioner, or para-medics. The applicant's plan bundled multiple medical and allied services over a long-term period, but the supporting material did not disclose the complete nature, scope, and conditions of the services or the terms of the tie-up arrangements with other hospitals. In the absence of the necessary documents and full particulars, it was not possible to verify whether the activities actually fell within the claimed exemption category.

Conclusion: The application was held to be not maintainable.

Ratio Decidendi: An advance ruling application may be rejected as not maintainable where the applicant fails to furnish sufficient particulars and supporting documents to determine the exact nature of the supply and its tax treatment.

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