A query regarding GST and Place of Supply:

A healthcare service provider located in Karnataka is providing a taxable health check-up package. The customer is a company registered under GST in Maharashtra (GSTIN starts with 27).

However, the company’s employees physically travel to Karnataka and undergo the complete health check-up at the healthcare provider’s premises in Karnataka.

In this case:

  1. Whether the Place of Supply should be considered Karnataka under Section 12(4) of the IGST Act, since the health service is actually performed in Karnataka?
  2. If the supplier and Place of Supply are both Karnataka, should the supplier charge CGST + Karnataka SGST, even though the recipient has a Maharashtra GSTIN?
  3. Or should IGST be charged merely because the recipient is registered in Maharashtra?
  4. Would the answer be different if the health check-up is provided as a package consisting of laboratory tests, diagnostic imaging and consultation?

Requesting views with reference to the relevant provisions/notifications and any practical experience.

Replies (1)
  • Place of Supply: Karnataka, by virtue of Section 12(4) (performance-based location for health services), which overrides the general B2B recipient-location rule under Section 12(2).

  • Tax Type: CGST + Karnataka SGST (intra-State supply under Section 8(1)), as both the supplier and the Place of Supply are in Karnataka, regardless of the recipient's Maharashtra GSTIN.

  • Packaging of Tests/Consultations: Does not alter the outcome; the package remains governed by the physical performance location in Karnataka.

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