GST on Doctor Consultation Fees in India: Exemption, SAC Code and When GST Applies
A doctor's consultation fee in India carries no GST. Health care services by a clinical establishment, a registered medical practitioner or para-medics are exempt under entry 74 of Notification No. 12/2017-Central Tax (Rate), and the exemption still stands. Cosmetic procedures and hair transplants fall outside it, because the definition of health care services leaves them out. So do medicines and products a clinic sells as separate items.
The exemption, word for word
Entry 74 of Notification 12/2017-Central Tax (Rate), under heading 9993, exempts at a nil rate:
"Services by way of- (a) health care services by a clinical establishment, an authorised medical practitioner or para-medics"
The same notification defines the terms. A clinical establishment includes "a hospital, nursing home, clinic, sanatorium or any other institution by, whatever name called, that offers services or facilities requiring diagnosis or treatment or care". An authorised medical practitioner is "a medical practitioner registered with any of the councils of the recognised system of medicines established or recognised by law in India".
Health care services means "any service by way of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognised system of medicines in India", and the definition ends with the exception that matters for skin and aesthetic clinics:
"but does not include hair transplant or cosmetic or plastic surgery, except when undertaken to restore or to reconstruct anatomy or functions of body affected due to congenital defects, developmental abnormalities, injury or trauma"
The CBIC's Circular 32/06/2018-GST repeats the position: "Health care services provided by a clinical establishment, an authorised medical practitioner or para-medics are exempt."
SAC codes for a clinic
The service codes (SAC) come from the annexure to Notification 11/2017-Central Tax (Rate). The ones a small clinic uses:
| SAC | Service |
|---|---|
| 999312 | Medical and dental services |
| 999314 | Nursing and physiotherapeutic services |
| 999316 | Medical laboratory and diagnostic-imaging services |
| 999319 | Other human health services, including homeopathy, unani, ayurveda, naturopathy and acupuncture |
The GST Council's explanatory notes describe 999312 as general medical services, "such as: a. consultations b. physical check-ups", whether delivered in an outpatient clinic, at home, or "by phone, Internet or other means". A teleconsultation falls in the same code as a visit.
Cosmetic procedures in skin and hair clinics
Because the definition of health care services leaves out hair transplant and cosmetic or plastic surgery, those services do not get the entry 74 exemption unless they restore or reconstruct the body after a congenital defect, developmental abnormality, injury or trauma. A dermatology clinic that treats acne, eczema or an infection is giving exempt health care. Where the same clinic does purely cosmetic work, that part of its billing needs separate treatment, so ask your tax adviser to split the two.
Physiotherapy
Physiotherapy has its own code, 999314, which the explanatory notes describe as services "provided by qualified practitioners, other than medical doctors". Whether a physiotherapy clinic's fees fall within the exemption turns on whether physiotherapists count as "para-medics" or as practitioners of a "recognised system of medicine", and Notification 12/2017 defines neither "para-medics" nor physiotherapy. We found no CBIC clarification on it, and advance rulings bind only the clinic that asked for them. If your physiotherapy clinic's yearly billing is close to the registration threshold, get a written opinion from a chartered accountant.
Medicines and products
The exemption is for services. A Gujarat advance ruling held that medicines from a hospital's own pharmacy, used in treating in-patients, are part of one composite in-patient health care service and so exempt (GUJ/GAAR/R/106/2020). Medicines, creams, supplements or devices that an outpatient clinic sells as separate items are goods, and GST on goods follows the goods rate schedules. We found no CBIC circular that settles this for outpatient clinics, so treat product sales as a question for your accountant.
Does a clinic need GST registration?
A clinic that only gives exempt health care services does not have to register. Section 23(1)(a) of the CGST Act excludes "any person engaged exclusively in the business of supplying goods or services or both that are not liable to tax or wholly exempt from tax".
A clinic that also sells taxable goods or services has to register once its aggregate turnover in a financial year crosses Rs 20 lakh (section 22(1)). In special category states the limit is Rs 10 lakh. Aggregate turnover includes exempt supplies (section 2(6)), so consultation fees count toward the limit even though they carry no tax. A clinic billing Rs 15 lakh in consultations and Rs 6 lakh in products has crossed it.
What to print on a fee receipt
GST is not charged on a consultation, so the receipt does not show a GST line. What it must show comes from the medical council's rules: the doctor's registration number. Clause 1.4.1 of the Indian Medical Council Regulations, 2002 requires every physician to display their registration number "in his clinic and in all his prescriptions, certificates, money receipts given to his patients". Dentists have the same rule in clause 3.4.1 of the Dental Council's code of ethics.
Our free OPD slip and fee receipt prints your registration number on the receipt. In MyClinicDesk, you enter the registration number once in Settings, every bill prints it, and the bill can go to the patient on WhatsApp.
This article summarises public notifications and is not tax advice. GST rules change by notification, so confirm your position with a chartered accountant.