No GST Relief On Group Health Insurance Premium | HC

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GST Exemption On Health Insurance Premium

Case Details: E.P. Gopakumar vs. Union of India [2026] 182 taxmann.com 231 (Kerala)

Judiciary and Counsel Details

  • Ziyad Rahman A.A., J.
  • V.K. Prasad, Smt. Josna C.F., Smt. Rintu Paul, V.M. Krishnakumar, Dr. Silpa Aziz, Advs. & Renjith Thampan, Sr. Adv. for the Petitioner.
  • Praveen K.S., Renjish S. Menon, Smt. Girija L., Smt. Sanjana R. Nair, Satheesh T.P., CGCs, P.R. Sreejith, P.T. Dinesh, Sr. Standing Counsels, V. Girishkumar, SC, P. Fazil, Jithin Paul Varghese, Fadil Fazil, Smt. Aswathy Jayachandran, George A. Cherian, Smt. M. Santhy, Smt. Latha Anand, Smt. Anna Rose Nambadan, S.Vishnu (Arikkattil), Sunil Shanker, Smt. Vidya Gangadharan, Thomas Glaison, C. Ajith Kumar, Smt. Varsha S.S., Smt. Rosanna C. Wilson, Dr. Pauly Mathew Muricken, H. Ramanan, Smt. Akshaya Thomas, Asvino Sheej S., Alan Philip Alex, Smt. Arathi Prabhakaran, P.R.Sreejith, Saju Thaliath, C. Prabitha, Advs. & George Cherian, Sr. Adv. for the Respondent.

Facts of the Case

The petitioners, who were retired bank employees, challenged the levy of GST on premiums paid towards group health insurance policies arranged through the Indian Banks’ Association. It was contended that the policies were procured to provide welfare benefits to retired bank employees and that collective arrangements should not exclude them from exemption. The Department of Revenue submitted that the exemption under the Notification applied only to health insurance services where the insured is not a group and that group policies with special rates and additional benefits, fall outside the scope of the exemption. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the exemption under Notification No. 16/2025-Central Tax (Rate) dated 17-9-2025 is intended to apply exclusively to individual health insurance policies and not to group insurance. It was held that the exemption is limited to services of a health insurance business provided to individual insured persons and does not extend to group policies based on arrangements reached between an association and an insurer. Consequently, GST is leviable on premiums paid by retired bank employees towards group health insurance policies, affirming the Department’s stance under Section 11 of the CGST Act and Kerala GST Act.

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied