AI Drafter 
TaxTMI 
TaxTMI 
2026 (2) TMI 717
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....cant by fraud or suppression of material facts or misrepresentation of facts, shall render such ruling to be void ab initio in accordance with Section 104 of the Act. 5. The provisions of both the Central Goods and Services Tax Act and the Tamil Nadu Goods and Services Tax Act (herein referred to as the Act) are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the Central Goods and Services Tax Act would also mean a reference to the same provisions under the Tamil Nadu Goods and Services Tax Act. The applicant is a multi-speciality hospital, engaged in the provision of comprehensive healthcare services to both inpatients and outpatients. The hospital operates with a team of qualified medical professionals, nursing staff, and paramedical personnel, and provides a range of medical services including diagnostic investigations, surgical procedures, outpatient consultations, emergency care, and inpatient hospitalization. 1.2 The applicant has sought advance ruling on the following questions :- 1. Whether the supply of medicines, consumables, implants, and medical items to In-patients ....
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....oices are common and not segregated between inpatient and outpatient usage. The inventory is tracked and managed centrally to ensure seamless operations and uniform service delivery. 3.5 The integrated nature of pharmacy and consumable supply operations ensures that there is no independent or stand-alone supply of medicines or consumables; rather, such items are issued solely as a part of patient treatment, forming an inseparable part of the overall healthcare service. 3.6 Inpatient Scenario When a patient is admitted to a hospital for inpatient care, the hospital provides a comprehensive treatment tailored to the patient's medical needs. This typically encompasses a broad range of services and goods that are necessary for the patient's treatment and recovery during the hospital stay. The key components included in this services are: 1. Room Charges: • Charges for the hospital room or bed, which may vary based on the type of room (e.g., general ward, semi-private, or private room). • Includes basic facilities such as bed linen, housekeeping, and other support services. 2. Medical and Nursing Services: • Continuous me....
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....pplies provided during the patient's admission are grouped into one comprehensive invoice. • This invoice includes-but is not limited to-the following components: • Room and nursing charges • Doctor consultation fees • Surgical and diagnostic procedures • Laboratory and imaging services • Medicines and consumables • While each component is itemized for transparency, they collectively form a composite supply, where the principal supply is inpatient healthcare service. • Unique Patient Identification (Inpatient vs Outpatient): • The hospital maintains separate unique patient identifiers for inpatient and outpatient services to ensure proper segregation of services, documentation, and billing. • This distinct ID system ensures that services provided to inpatients are clearly differentiated from outpatient services. • The separate IDs facilitate accurate treatment mapping, clinical record maintenance, and compliance with GST audit requirements. • The system facilitates seamless integration with hospital information systems (IIIS), e....
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.... 4.4 The applicant seeks clarity on whether the supply of medicines, consumables, implants and other goods used in the course of treatment to inpatients and outpatients in a hospital, being part of healthcare services, is exempt from GST under the said notification. 5.1 Statement of the Applicant's Interpretation of Law: Legal Provisions Involved: • Section 97(2)(b) of the CGST Act, 2017: Classification of any goods or services or both. • Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, Entry 74: "Health care services by a clinical establishment, an authorized medical practitioner or paramedics" are exempt from GST." • Explanation (zg) to Entry 74 of the said Notification: "Health care services" means any service by way of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognized system of medicines in India and includes services by way of transportation of the patient to and from a clinical establishment." • "Clinical establishment" means a hospital, nursing home, clinic, sanatorium or any other institution that offers services requiring diagnosis or treatment." ....
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....empt. 4) Medicines to outpatients / Public are independent supply of goods -> taxable at respective HSN rates. Further, they stated that there are no pending proceedings, or, proceedings already decided, as per the Liability registers in respect of this taxpayer. 6.3 Since, no remarks has been received from the Central GST jurisdictional Authorities, it is construed that there are no pending proceedings against the applicant on the questions raised by them in their advance ruling application. PERSONAL HEARING 7.1 Personal hearing was held on 17.12.2025. Shri. N Gokul Kishore, GST Practitioner and Authorized Representative (AR) of M/s. Rajarajeswari Hospitals Private Limited appeared for the personal hearing. 7.2 The AR reiterated the submissions made under the Application for Advance Ruling filed by them. AR explains the facts of the case and furnished additional submissions during the personal hearing. AR informed that the applicant is multi-specialty hospital engaged in providing comprehensive healthcare services to inpatients and outpatients. The hospital has in-house pharmacy and stores department and are holding drug license for procuring and dispensing....
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....rol and billing mechanism of the hospital. Medicines and related items are issued exclusively to patients receiving treatment, both inpatients and outpatients, based on valid prescriptions from the hospital's medical personnel. 8.4 To begin with, we note that 'Health care' services provided by a clinical establishment or an authorized medical practitioner or paramedics are exempted vide Sl. No. 74 of Notification No. 12/2017-C.T. (Rate) dated 28.06.2017, as amended. For ease of reference, the relevant entry is reproduced below :- SI.No Chapter, Section, Heading, Group or Service Code (Tariff) Description of Services Rate (percent) Condition 74 Heading 9993 Services by way of - a) health care services by a clinical establishment, an authorised medical practitioner or para-medics; b) services provided by way of transportation of a patient in an ambulance, other than those specified in (a) above. Nil Nil "Clinical Establishment" is defined in the said notification under 2(s), as, "Clinical Establishment" means a hospital, nursing home, clinic, sanatorium or any other institution by, whatever name called, that offers servic....
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.... of a patient. ii) Gynaecological and obstetrical services delivered under the direction of medical doctors to inpatients, aimed at curing, restoring and/or maintaining the health of a patient. iii) Psychiatric services delivered under the direction of medical doctors to inpatients, aimed at curing, restoring and/or maintaining the health of a patient. iv) Other hospital services delivered under the direction of medical doctors to inpatients, aimed at curing, restoring and/or maintaining the health of a patient. These services comprise medical, pharmaceutical and para medical services, rehabilitation services, nursing services and laboratory and technical services, including radiological and anaesthesiological services, etc. Thus, 'Inpatient services' means services provided by hospitals to inpatients under the direction of medical doctors aimed at curing, restoring and/or maintaining the health of a patient and the service comprises of medical, pharmaceutical and paramedical services, rehabilitation services, nursing services and laboratory and technical services till the patient gets discharged. A complete gamut of activities required for the well-be....
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....e 'Healthcare services', which happen to be the principal supply. Therefore, supply of medicines and consumables including food to in-patients in the course of the treatment till the patient is discharged is a composite supply of health care services. 8.10 In this regard, we find that under the additional submissions made during the personal hearing, the applicant has stated further that the issue is no longer res integra and that the same is squarely covered by multiple Advance Rulings in the state of Tamil Nadu, which have consistently held that supply of medicines to in-patients is part of exempt healthcare services, as in the cases involving M/s. Shifa Hospitals, M/s. Maha Critical Care Speciality Division, M/s. Kovai Medical Center and Hospital Ltd., M/s. PSG Hospitals, M/s. G. Kuppuswamy Naidu Memorial Hospital and M/s. MGM Healthcare Pvt. Ltd., Apart from the same, we find that in the application for advance ruling filed by them, the applicant has referred and discussed the cases relating to M/s. Be Well Hospitals (P) Ltd., (AAR, Tamil Nadu), and M/s. St. Thomas Hospital [AAR, Kerala). Here again, we find that both the aforesaid cases discuss about the supply of medicines....