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Advance rulings (AAR) Goa

GST Exemption for Ayurveda and Naturopathy Health Care Services

Ayurveda and nature cure centers providing doctor-supervised treatments qualify for GST exemption as health care services.

Ruling
GOA/GAAR/6/2018-19 dated 22/01/2019
Authority
Authority for Advance Ruling

This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.

The short version

  1. Alcon Resort Holdings asked if their wellness services are exempt from GST.
  2. The authority ruled these services qualify as health care under Notification 12/2017.
  3. Medicines and diet provided during treatment are part of a composite supply.
  4. The entire service package is eligible for a NIL rate of GST.

In short

The company asked if their Ayurveda, Naturopathy, and Yoga center could claim a GST exemption for their integrated treatment packages. These packages include doctor consultations, therapies, medicines, and specialized diets. The authority examined whether these combined services count as exempt health care under the Goods and Services Tax (GST) law.

What has changed

How it worked before

It was unclear whether wellness centers providing a mix of medical treatments and hospitality services could claim the same tax exemptions as traditional hospitals.

What has changed

The authority confirmed that these integrated wellness services are a composite supply, meaning the medicines and diet are naturally bundled with the medical treatment. Because the center operates as a clinical establishment, the entire service is exempt from GST. This provides clarity for similar centers that their holistic treatment plans do not attract tax.

Who this affects

Owners of Ayurveda, Naturopathy, Yoga, and other holistic wellness centers that provide doctor-supervised medical treatments.

An example

A wellness center in Kerala provides Ayurvedic treatments for chronic back pain, including doctor consultations and prescribed herbal medicines. They wonder if they must charge GST on the total bill. Based on this ruling, if they operate as a clinical establishment, their integrated treatment package is likely a composite supply exempt from GST.

What you should do

If you run a similar center, review your service model against the criteria for a clinical establishment. Remember that an Advance Ruling only binds the business that asked and its specific tax office. You should consult with your tax advisor to see if your specific service structure qualifies for this exemption before stopping tax collection.

If you do nothing

If you assume this ruling applies to you and stop paying GST without confirming your status, you risk a tax demand notice. If your local tax officer disagrees with your classification, you may be liable for unpaid taxes, interest, and penalties. Always seek a professional opinion specific to your business operations.

The terms explained

Composite supply
A package of two or more goods or services that are naturally bundled together and provided as a single unit in the ordinary course of business.
Clinical establishment
A hospital, nursing home, or clinic that provides medical care and is recognized by the government as a place for diagnosis and treatment.
NIL rate of tax
A tax rate of zero percent, meaning no GST is payable on the service.

The ruling in detail

Authority for Advance Ruling

Alcon Resort Holdings Private Ltd.

GOA/GAAR/6/2018-19 dated 22/01/2019 · Goa

Questions before the authority

  • Whether the service provided by the applicant (including all incidental services) amounts to a composite service under the classification of health care services exempt under Entry No. 74 of Notification 12/2017 – Central Tax.

Facts

The applicant operates a centre named Devaaya Ayurveda & Nature Cure, providing health care services through Ayurveda, Naturopathy, and Yoga. Patients receive treatments for various conditions, including neuro-muscular problems, chronic allergies, and metabolic issues. The services include consultation, diagnosis, therapy, and the provision of medicines and diet under the supervision of qualified doctors.

Ruling

QuestionWhat the authority ruled
Exemption status of health care servicesExempt
Classified as a composite supply of health care services

The authority held that the services provided by the applicant qualify as health care services. Consequently, these services are eligible for exemption under Entry No. 74 of Notification No. 12/2017 – Central Tax.

Reasoning

The authority determined that the applicant qualifies as a clinical establishment and that the services provided are health care services as defined in the notification. It concluded that the supply of medicines, consumables, and implants in the course of treatment is naturally bundled with the health care services. Therefore, the entire arrangement constitutes a **composite supply** eligible for the **NIL rate of tax** under the specified notification.

Provisions relied on

  • Section 97(2) of the CGST/GGST Act, 2017
  • Section 98 of the CGST/GGST Act, 2017
  • Notification No. 12/2017 – Central Tax (Rate) dated 28th June, 2017

For the practitioner

This ruling confirms that holistic wellness centres providing integrated medical treatments under doctor supervision can qualify as clinical establishments for GST exemption purposes. It clarifies that the supply of medicines and diet as part of a treatment plan is considered a **naturally bundled composite supply**. Practitioners can use this to support claims for exemption for similar integrated health care models, provided they meet the clinical establishment criteria.

Source

This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.

Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/goa-gaar-6_dt.22.01.2019_arhpl.pdf

Legibility of the scan, as read: high.

Prepared 20-10-2026.

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Does this ruling mean all wellness centers are exempt from GST?

No. This ruling applies specifically to the applicant. Your center must meet the definition of a clinical establishment and provide medical treatments under doctor supervision to qualify.

Is this ruling binding on my tax officer in another state?

No. An Advance Ruling is only binding on the business that requested it and the tax authorities in that specific jurisdiction.

What if my center provides spa services alongside medical treatments?

The ruling focuses on medical treatments. If your services are primarily for relaxation or luxury rather than medical care, they may not qualify for the exemption.

How do I know if my center is a clinical establishment?

You should check your registration documents and local state health department requirements. A clinical establishment must be equipped to provide medical diagnosis and treatment.