TaxTMI 
TaxTMI 
2025 (3) TMI 313
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....few specific provisions. Therefore, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act, 2017 would also mean reference to the corresponding similar provisions in the GGST Act, 2017. 2. The present appeal is filed under section 100 of the CGST Act, 2017 and the GGST Act, 2017 by M/s. Divyajivan Healthcare Pvt. Ltd. (for short 'Appellant') against the Advance Ruling No. GUJ/GAAR/R/01/2022 dated 07.01.2023. 3. Briefly, the facts are enumerated below for ease of reference: 4. The appellant has devised a plan, namely "Health Care Service (Diamond Plan)" wherein the appellant shall provide the health care services for next 20 years for which a lump-sum amount, say Rs. 10 lakhs will be charged. ....
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....h are home care services, priority OPD appointments in tie-up hospital, tele-medical guidance through application. 6. The appellant further stated that they will digitalize the health records based on the above tests and treatments of the beneficiary members for their easy access and shall also provide regular reminders updates and health education tips. 7. In view of the foregoing facts, the appellant had sought Advance Ruling on the following questions, viz: "Whether lump-sum amount received for Health care Services to be provided for 20 years by the applicant as "Diamond Plan" is exempted from Goods and Services Tax as per Sr. No. 74 of Notification No. 12/2017-Central Tax." 8. Consequent to hearing the applicant, the Gujarat Author....
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....maintainable." 10. Aggrieved, the appellant is before us, raising the following contentions, viz * that the services proposed to be provided by them are health care services and the same are exempted under Sr. No. 74 of the of notification No. 12/2017-Central Tax (Rate) dt. 28.06.2017; * that they had submitted detailed nature and characteristics of services under Diamond Plan; * that the person availing "Health Care Service (Diamond Plan)" cannot get treatment or care for illness at a hospital of his/her choice nor can he claim any reimbursement for getting treatment/care for illness at any hospital, other than the hospital of the appellant or the hospital suggested by the appellant. 11. Personal hearing in the matter was held on 2....