In re Ayushya Ayurvedic and Panchakarma Centre (Padmanabha Pillai Sambhu) (GST AAR Kerala)
The Kerala Authority for Advance Ruling (AAR) examined whether healthcare services provided by an Ayurvedic hospital, including medicines and ancillary services supplied during inpatient treatment, qualify for GST exemption under Entry No. 74 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
The applicant, M/s. Ayushya Ayurvedic and Panchakarma Centre, is an Ayurvedic clinical establishment in Thiruvananthapuram providing inpatient and outpatient healthcare services. The applicant submitted that inpatients are admitted through a formal process, allotted rooms, and provided treatment, medicines, consultations, and procedures under continuous medical supervision. Consolidated bills are issued for inpatient treatment covering consultation charges, medicines, room accommodation, and related procedures. Outpatients, however, receive consultations and may separately purchase medicines based on prescriptions.
The applicant contended that services provided to inpatients constitute a single composite supply of healthcare services in which medicines, consumables, room rent, and ancillary services are naturally bundled and inseparable from the principal healthcare service. Accordingly, the applicant argued that such services should qualify for exemption under Entry No. 74 of Notification No. 12/2017-Central Tax (Rate) The applicant also acknowledged that medicines supplied independently to outpatients may constitute separate taxable supplies liable to GST.
