GST Exemption on Healthcare Services Available Even When Rendered Through Another Hospital Under Revenue-Sharing Arrangement

The Hon’ble Karnataka High Court in Healthcare Global Enterprises Ltd. v. Assistant Commissioner of Commercial Taxes [Writ Petition No. 22236 of 2023 dated April 30, 2026] quashed the Show Cause Notices issued under Section 73 of the CGST Act, 2017 seeking to tax the services rendered by the Petitioner under SAC 9985 as “Support Services” at 18% GST, and held that the benefit of exemption under Sl. No. 74 – Heading 9993 of Notification No. 12/2017-Central Tax (Rate) dated June 28, 2017, which unconditionally exempts healthcare services from payment of GST, will be available even when the services are provided by a hospital/clinic to the patient through another hospital/clinic under a revenue-sharing arrangement.

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