Interactive Tool • Section 35AD, 194J & GST Room Rent

Healthcare & Hospital Compliance Evaluator

Model Section 35AD 100-bed hospital Capex deductions, calculate Notification 12/2017 5% room rent GST liability (> ₹5,000/day), audit Doctor Retainership TDS risk (§ 194J vs § 192), and delineate IPD Composite vs OPD Pharmacy tax splits. Computations execute 100% locally in your browser with zero server data storage under the DPDP Act 2023.

Clinical & Operational Parameters

Determines Section 35AD specified business deduction eligibility.

Building & medical equipment (excl. land)

Non-ICU room rate per patient per day

Professional fees to visiting consultants

Medicines & implants billed to admitted patients

Outpatient counter retail sales to walk-in patients

Statutory Diagnostics

Live Audit Simulation
Section 35AD Deduction 100% Capex Write-Off

Qualifying 100+ Bed Hospital

100% upfront capital deduction on building and medical plant under Section 35AD.

Eligible Capex Deduction: ₹25,00,00,000
Est. Corporate Tax Shield (~25.17%): ₹6,29,25,000
Room Rent GST (Entry 74) 5% GST Taxable

Tariff Exceeds ₹5,000 / Day

Room charges above ₹5,000/day attract 5% GST without Input Tax Credit.

Daily Room Charge: ₹7,500
Applicable GST per Bed-Day (5%): ₹375
ICU, CCU, ICCU, and NICU bed charges remain 100% exempt.
Doctor TDS Classification Section 194J Compliant

Independent Professional Retainer

10% TDS under Section 194J supported by written fee-sharing agreement with zero master-servant attributes.

Annual Visiting Doctor Payouts: ₹6,00,00,000
Statutory TDS Withholding: ₹60,00,000 (10%)
Low reassessment risk under Section 201 assessee-in-default scrutiny.
Pharmacy GST Split Composite Delineation
Inpatient (IPD) Pharmacy: 100% Exempt (Sec 2(30))
Outpatient (OPD) Retail: Taxable (5%/12%/18% + ITC)

ERP must maintain separate billing series and dispensing records to defend against GST Rule 42/43 ITC reversal notices.

Statutory Framework for Healthcare Facilities & Hospitals

1. Section 35AD Capex Incentive & 100-Bed Mandate

Under Section 35AD of the Income-tax Act, 1961 (and Section 35AD of the Income-tax Act, 2025), a taxpayer building and operating a new hospital with at least 100 beds for patients is entitled to an immediate 100% deduction on all capital expenditure incurred exclusively for the business (excluding land, goodwill, and financial instruments). An electronic audit report in Form 3CE certified by an independent Chartered Accountant with UDIN must be furnished before the statutory deadline.

2. Notification 12/2017 Entry 74 Room Rent GST Proviso

While clinical healthcare services provided by clinical establishments, authorized medical practitioners, or paramedics are broadly exempt from GST under Entry 74, Notification No. 04/2022-CT(Rate) introduced an express carve-out: room charges (excluding ICU, CCU, ICCU, and NICU) exceeding ₹5,000 per day attract 5% GST without Input Tax Credit. Hospital billing ERP systems must segregate room tariff components to eliminate tax leakage and statutory audit discrepancies.

3. Doctor Retainership: Section 194J vs Section 192 Exposure

The characterization of remuneration paid to visiting consultants is heavily scrutinized during TDS surveys. Where retainers lack fixed hours, receive variable fee shares, and maintain independent practice, 10% withholding under Section 194J applies. However, where contracts mandate fixed shift rosters, hospital leave rules, and exclusivity, revenue authorities seek reclassification under Section 192 salary TDS, issuing Section 201(1) assessee-in-default orders with 30% expenditure disallowance under Section 40(a)(ia).

4. IPD Composite Supply vs OPD Pharmacy Retail GST

Medicines, implants, and consumables administered to admitted in-patients (IPD) form an indivisible part of a composite healthcare supply under Section 2(30) of the CGST Act, rendering them 100% tax-exempt. Conversely, OTC medicines and supplies dispensed to outpatients (OPD) constitute independent supplies of goods taxable at 5%, 12%, or 18% with corresponding ITC eligibility. Strict dual-inventory accounting is mandatory to avert Rule 42 ITC reversal demands.

Require Healthcare Statutory Audit or Capex Structuring?

Consult our Healthcare Practice Desk for Section 35AD certifications, Doctor TDS contracts, and Room Rent GST ERP mapping.

Consult Healthcare Desk
ICAI Code of Ethics Pull-Model Statutory Notice This interactive diagnostic tool provides computational simulations for informational and planning purposes under direct and indirect tax statutes. Final tax positions require independent audit validation with formal UDIN.