Levy of GST— In the instant case, the applicant M/s Krishna Institute of Medical Sciences Limited is a public limited Company, and a multi-speciality hospital, rendering healthcare services and claiming exemption on the said service vide notification no. 12/2017 Central Tax Rate.

The applicant seeks advance ruling on the following:

1. Whether administering of COVID-19 vaccination by hospitals is Supply of Good or Supply of Service?

2. Whether administering of COVID-19 Vaccine by clinical establishments (Hospitals) qualify as "Health care services" as per Notification No. 12/2017 Central Tax Rate dated 28.06.2017?

3. Whether administering of COVID-19 vaccination by clinical establishment is exempt under GST Act?

The issue at hand is to decide whether administering of COVID-19 vaccination by hospitals is Supply of Goods or Supply of Service. Subsequently, the applicant seeks clarification whether administering of COVID-19 Vaccine by clinical establishments (Hospitals) qualify as "Health care services" as per Notification No. 12/2017 Central Tax Rate dated 28.06.2017 and eligible for exemption.

 Basically, two activities are involved in this transaction, 'sale of vaccine' under 'supply of goods' and 'administering of vaccine' under 'supply of service'. When it comes to administering of the vaccine by hospitals, it involves a combination of two supplies, which are naturally bundled, i.e, 'supply of vaccine' and the 'service component' followed by way of administering the same.

There is no doubt that the applicant qualifies to be a clinical establishment but, the supply transaction is predominantly of sale of goods and not the service component of healthcare.

Held that— It is a Composite supply, wherein the principal supply is the 'sale of vaccine' and the auxiliary supply is the service of 'administering the vaccine' and the total transaction is taxable at the rate of principal supply i.e, 5%.

Administering of COVID-19 Vaccine by clinical establishments (Hospitals) is not qualify as "Health care services" as per Notification No. 12/2017 Central Tax Rate dated 28.06.2017.

Administering of COVID-19 vaccination by clinical establishment is not exempt under GST Act.