Healthcare services exemption upheld for dermatological treatment, where services were genuine diagnosis and care rather than cosmetic procedures.

Healthcare services provided through qualified medical professionals for diagnosis and treatment of recognised dermatological conditions fall within the exemption in Sl. No. 74 of Notification No. 12/2017-Central Tax (Rate). The exemption applies only where the service is rendered by a clinical establishment, authorised medical practitioner or para-medics and answers the definition of healthcare services, which covers treatment of illness or abnormality and excludes purely cosmetic or plastic procedures except limited restorative cases. On the record, the services were supported by prescriptions, diagnostic reports and patient records, and were not mere aesthetic enhancement; they were therefore exempt.

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Issues: Whether healthcare services rendered for treatment of psoriasis, dandruff, dermatitis, anti-fungal infections, folliculitis, and similar dermatological conditions are exempt under Sl. No. 74 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Analysis: The exemption under Sl. No. 74 applies to healthcare services provided by a clinical establishment, an authorised medical practitioner, or para-medics. For the benefit to apply, the service must answer the definition of healthcare services in paragraph 2(zg) of the Notification and be provided by an entity that qualifies as a clinical establishment under paragraph 2(s). The definition covers diagnosis, treatment or care for illness, injury, deformity, abnormality or pregnancy in a recognised system of medicine, while excluding hair transplant and cosmetic or plastic surgery except in the limited restorative situations stated in the Notification. The record showed that the applicant's services were rendered through qualified medical professionals, supported by consultation forms, prescriptions, diagnostic reports and patient records, and related to recognised medical conditions rather than mere beautification or aesthetic enhancement.

Conclusion: The services are healthcare services falling within the exemption and are covered by Sl. No. 74 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Ratio Decidendi: A service is exempt under Sl. No. 74 only if it is genuine healthcare involving diagnosis or treatment of illness or abnormality by a clinical establishment, and not a purely cosmetic or aesthetic procedure.

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