Classification of service— The present appeal has been filed by M/s. Krishna Institute of Medical Sciences Limited against the Advance Ruling issued by Authority for Advance Ruling, Andhra Pradesh.

The Appellant sought clarification with regard to the activity of administering of COVID-19 vaccination by hospitals and approached the Authority for Advance Ruling on the following questions:

Question: Whether administering of COVID-19 vaccination by hospitals is Supply of Good or Supply of Service?

Question: 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?

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

The Authority for Advance Ruling Andhra Pradesh

Answer: Administering of COVID-19 vaccination by hospitals 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%.

Answer: Administering of COVID-19 Vaccine by clinical establishments (Hospitals) is not qualify under “Health care services” as per Notification No. 12/2017 Central Tax Rate dated 28.06.2017 and not eligible for exemption.

In the present case, the service rendered by the appellant is administration of Covid-19 vaccine which is also called Vaccination or Immunization. In order to find out whether the service of administering a vaccine fits into the “Health Care Services” exempted vide Notification No. 12/2017 Central Tax (Rate) dt.28.06.2017, we need to understand the term 'Vaccination'.

While validating the decision of the lower authority that taxability of the supply comes under '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%.

Held that— With the foregoing, we confirm and uphold the ruling of the AAR.