GST on counselling and therapy services

Entry 74 of Notification 12/2017-Central Tax (Rate) sets a nil rate for "health care services by a clinical establishment, an authorised medical practitioner or para-medics". The notification defines these terms:

• Health care services: "any service by way of diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognised system of medicines in India".
• Authorised medical practitioner: "a medical practitioner registered with any of the councils of the recognised system of medicines established or recognised by law in India", including a professional with the qualification to practise under any law in force.
• Clinical establishment: "a hospital, nursing home, clinic, sanatorium or any other institution by, whatever name called, that offers services or facilities requiring diagnosis or treatment or care for illness, injury, deformity, abnormality or pregnancy in any recognised system of medicines in India", or a place set up to carry out diagnostic or investigative services.

The notification does not define "para-medics", and the GST Act and its notifications do not define "recognised system of medicines" (as the West Bengal advance ruling notes). That is where the uncertainty for therapists comes from.

A second entry, 74A, added from 1 January 2019, exempts services by rehabilitation professionals recognised under the Rehabilitation Council of India Act, 1992 "by way of rehabilitation, therapy or counselling", but only at medical establishments, educational institutions and rehabilitation centres established by the Central Government, a State Government or Union territory, or an entity registered under section 12AA of the Income-tax Act. A private practice is outside that condition.

The exemption turns on what the service is and who supplies it, and the notification never names psychologists or counsellors. A psychologist working for a clinic is covered when the clinic is a clinical establishment supplying health care. A psychologist in private practice is covered only if they count as an authorised medical practitioner or a para-medic, and the notification does not say whether registration with the Rehabilitation Council of India makes someone either.

Treating a psychologist's sessions as exempt is therefore a reading of the law, not a rule written in it. Agree the position with your CA, write down the reasoning, and apply it the same way on every invoice.

• In May 2025 the Kerala Authority for Advance Ruling (KER/14/2025, Radiantminds Rehab LLP) held that the rehabilitation services of that LLP, delivered by RCI-recognised professionals including occupational therapists, speech therapists and psychologists, were not exempt under entry 74A and were taxable at 18% (as reported by StudyCafe; we could not find the ruling itself).
• In March 2020 the West Bengal Authority for Advance Ruling held that a company offering "phytotherapy" for osteoarthritis had not shown its treatment was in a recognised system of medicine, so entry 74 did not apply (order 46/WBAAR/2019-20).
• We found no ruling directly on a solo counsellor, psychotherapist or life coach. Under section 103 of the CGST Act an advance ruling binds only the business that asked for it and its tax officers, but rulings show how authorities read the law.

If a service is not exempt, therapy and counselling usually sit under heading 9993, human health and social care services, at 18% (9% central tax and 9% state tax) under Notification 11/2017-Central Tax (Rate). Coaching, corporate workshops and wellness programmes are taxable services too; ask your CA which heading and rate applies.

Under section 23(1)(a) of the CGST Act, "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" is not liable to register. If any of your work is taxable, section 22(1) requires registration once your aggregate turnover in a financial year exceeds twenty lakh rupees, or ten lakh rupees in the special category states. Aggregate turnover includes exempt supplies (section 2(6)), so exempt session fees count toward the limit once you also earn taxable income such as workshop fees.

A registered practitioner who supplies exempt services issues a bill of supply for them instead of a tax invoice (section 31(3)(c)). Our guide to invoices and payments covers what each document needs.