GST on doctor consultation fees: must a clinic register? The exemption, the word "exclusively", and what a clinic sells that is taxable.

No. Consultation fees are exempt from GST, and a clinic that earns only consultation and treatment fees does not need GST registration, however large its turnover. The exemption is serial number 74 of Notification No. 12/2017-Central Tax (Rate), dated 28 June 2017, and the registration rule is section 23(1)(a) of the Central Goods and Services Tax Act, 2017, which excludes anyone engaged exclusively in supplying exempt goods or services. The answer changes when the clinic also sells something taxable, such as cosmetic procedures, products over the counter or space to another business. Then the ₹20 lakh threshold applies, and it is counted on the clinic's whole turnover, consultations included.

Our post on closing the day across cash, UPI and card quotes the exemption and the threshold in two paragraphs. This one goes through the definitions, what falls outside them, how the threshold is counted, and what an advance ruling can and cannot settle.

What exactly is exempt?

Serial number 74 of Notification 12/2017, under Heading 9993, exempts at a Nil rate "(a) health care services by a clinical establishment, an authorised medical practitioner or para-medics; (b) services provided by way of transportation of a patient in an ambulance". Three definitions in paragraph 2 of the same notification decide whether your clinic is inside it.

The entry sets no fee limit. A ₹300 consultation and a ₹3,000 consultation are equally exempt. The only price-based carve-out in entry 74 is for hospital rooms, added on 13 July 2022 (see the table below).

Visiting consultants are covered as well. CBIC Circular No. 32/06/2018-GST, 12 February 2018, answered a question about doctors hired by hospitals without an employment contract: "Services provided by senior doctors/ consultants/ technicians hired by the hospitals, whether employees or not, are healthcare services which are exempt." The same circular says the whole amount a hospital charges the patient, "including the retention money and the fee/payments made to the doctors etc.", is towards exempt healthcare services. The circular speaks of hospitals. A clinic is also a clinical establishment under paragraph 2(s), but if your clinic keeps a share of a visiting specialist's fee, have your CA confirm the arrangement.

Does a consultation-only clinic need GST registration?

No. Section 22(1) of the CGST Act makes a supplier liable to register when it "makes a taxable supply" and its aggregate turnover in a financial year exceeds ₹20 lakh (₹10 lakh in the special category States). Section 23(1)(a) then takes out "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 whose every rupee comes from exempt health care services falls inside that exclusion at any turnover.

The word to watch is "exclusively". At most OPDs the consultation is the business, but small extras creep in over the years: a shelf of skin-care products, a cosmetic package, a corner rented to a sample collection centre. Each of those is a separate supply. If one of them is taxable, the clinic is no longer engaged exclusively in exempt supplies, and section 22 decides the question instead.

A clinic may still register voluntarily. Section 25(3) allows a person not liable under section 22 to register, and "all provisions of this Act, as are applicable to a registered person, shall apply to such person". Registration is a set of continuing duties, so ask your CA why it is needed before doing it.

What a clinic sells that is not exempt

Section 9(1) of the CGST Act levies tax "on all intra-State supplies of goods or services or both" at the notified rates. Anything not covered by an exemption is taxable. These are the lines that show up at small clinics, with the text that decides each.

The room-rent line matters to day-care and nursing-home setups, not to a plain OPD. We have not stated product rates here: medicine and cosmetic rates sit in separate goods notifications and change with GST Council decisions, so take the rate for each product from your CA or the current CBIC notification.

How is the ₹20 lakh threshold counted?

On aggregate turnover, and that includes the exempt fees. Section 2(6) of the CGST Act defines aggregate turnover as "the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis", excluding the GST itself. The threshold is not measured on the taxable sales alone.

Clinic B's taxable sales are only ₹1,50,000, but the exempt fees push its aggregate turnover past the limit. On the words of sections 2(6), 22 and 23 that is enough. This is the case to take to your CA.

Two details of the threshold. The lower ₹10 lakh limit applies in the special category States, which section 22 defines by reference to article 279A(4)(g) of the Constitution, excluding Jammu and Kashmir, Arunachal Pradesh, Assam, Himachal Pradesh, Meghalaya, Sikkim and Uttarakhand. And under section 25(1), a person who becomes liable must apply for registration within thirty days.

If the clinic registers, does it charge GST on consultations?

No. Registration does not make the consultation taxable; the exemption is about the service, not about who supplies it. What changes is the paperwork. Under section 31(3)(c), a registered person supplying exempted services issues "instead of a tax invoice, a bill of supply". The taxable products or services get a tax invoice with GST. Your receipt book or billing software has to tell the two apart, and the counter staff need to know which is which.

What an advance ruling can and cannot tell you

Many GST answers for healthcare online quote advance rulings. Read them for reasoning, not as law for your clinic. Section 103(1) of the CGST Act says an advance ruling is binding only on the applicant who sought it and on the officers who deal with that applicant, and section 103(2) adds that it stays binding only while the law, facts and circumstances are unchanged.

One example is the Tamil Nadu Authority for Advance Ruling's order of 25 November 2019 for CMC Vellore Association. It ruled that "Medicines, drugs, stents, consumables and implants used in the course of providing health care services to in-patients admitted to the hospital for diagnosis, or medical treatment or procedures is a composite supply of In Patient Healthcare Service", exempt under serial number 74. That ruling binds only the applicant, and it is about admitted patients. It says nothing about a clinic selling medicines to OPD patients over the counter.

Income tax has its own, separate threshold

Doctors often mix the GST limit up with the income-tax presumptive limit. They are unrelated. From 1 April 2026 the Income-tax Act, 2025 applies (section 1(3)). Section 62(4) lists "medical" as a specified profession, and serial number 3 of the table in section 58(2) lets a resident individual or a firm (other than an LLP) in a specified profession treat 50% of gross receipts as profit, or the profit actually earned if higher. It applies where gross receipts do not exceed ₹50 lakh, or ₹75 lakh where cash received does not exceed 5% of gross receipts.

Section 58(9) treats a cheque or draft that is not account payee as cash for that 5% test. Under section 58(3), a doctor who claims profit lower than the 50% figure, and whose income is above the taxable limit, must keep books under section 62 and get them audited under section 63. Whether this scheme suits you is a question for your CA.

What to take to your CA

1. A list of everything the clinic charges for, in one line each: consultation, procedures, dressings, injections given in the clinic, certificates, products, rent from anyone using your space, packages.
2. For each procedure, whether it is cosmetic. Para 2(zg) of Notification 12/2017 is the test, and only the reconstructive cases listed there stay exempt.
3. Last year's total collections, split into consultation and treatment fees and everything else. The monthly roll-up from the day-close routine gives you this.
4. Any rent or licence agreement for space you let out, and any arrangement where a visiting doctor's fee passes through the clinic.
5. Your State, so the CA can apply the right threshold.
6. If you are already registered: whether consultations go out on a bill of supply and products on a tax invoice.