Name of the Case: M/S. Stemcyte India Therapeutics Pvt Ltd v. C.C.E. And St, Ahmedabad
Citation: 2025 INSC 841
Hon’ble Supreme Court’s Bench: Justice JB Pardiwala and Justice R Mahadevan
Date: 14.07.2025
In a significant judgment interpreting the scope of tax exemptions under Indian service tax law, the Hon’ble Supreme Court held that stem cell banking services provided to preserve umbilical cord blood for future therapeutic use, falls within the ambit of “healthcare services”. The Hon’ble Court clarified that the nature of service provided by the appellant is aimed at medical treatment in the future and is closely linked to the diagnosis, treatment, or care of illness or injury. Hence, it squarely qualifies for exemption under Entry No. 2 of the notification.
Rejecting the contention that such services are speculative or do not involve actual treatment, the Hon’ble Court emphasized that preventive and preparatory healthcare measures are also part of healthcare services, especially when the purpose is to ensure therapeutic utility. The Hon’ble Bench finally concluded that a narrow interpretation of healthcare services would defeat the purpose of medical advancement and public interest. Accordingly, the demand for service tax was set aside and the tax exemption was allowed1.
- https://api.sci.gov.in/supremecourt/2024/47253/47253_2024_9_1505_62294_Judgement_14-Jul-2025.pdf
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