In re Amala Cancer Hospital Society (GST AAR Kerala)
The Goods and Services Tax (GST) Authority for Advance Rulings (AAR) in Kerala has provided clarification regarding GST applicability on various services and supplies offered by Amala Cancer Hospital Society, a multi-specialty hospital. The hospital sought an advance ruling on the taxability of medicines, implants, and other supplies to both inpatients and outpatients under different billing scenarios, including packaged treatments and itemized billing.
The AAR’s ruling highlighted that “healthcare services” are generally exempt from GST under Serial No. 74 of Notification No. 12/2017 CT (Rate). For inpatients, any supplies “naturally bundled” with healthcare services are also considered exempt as a composite supply, with healthcare being the principal supply (as per Section 8(a) of the CGST Act). However, the AAR declined to issue a general ruling for scenarios involving “wholesome packages,” “limited packages,” or “separately billed at actual” charges for inpatients because the applicant’s inclusion of “other required supplies” could potentially encompass items not naturally bundled with healthcare services. For example, specific facilities for bystanders or room rent exceeding 竄ｹ5,000 per day (which is specifically outside the exemption) would need to be examined on a case-by-case basis to determine their taxability, preventing a blanket ruling.
