GST and Invoicing for Therapists in India

Most solo therapists in India don’t need GST registration until their aggregate turnover passes ₹20 lakh in a financial year. Below that you don’t register or charge GST, and you issue plain numbered invoices. Above it, the question is whether your services are exempt “health care services”, which turns on what you deliver and your qualifications. Therapy sessions and corporate workshops can land on opposite sides of that line, which is why the most useful habit is keeping them apart in your books from the start.

When registration is required

Section 22 of the CGST Act makes a supplier liable to register once aggregate turnover in a financial year exceeds ₹20 lakh, or ₹10 lakh in special category states. For service providers, the GST Council’s own registration guide names Manipur, Mizoram, Nagaland and Tripura as the ₹10 lakh states. Three details catch therapists out:

1. Aggregate turnover includes exempt income. The Act defines it (Section 2(6)) as the value of taxable supplies, exempt supplies, exports and inter-state supplies under the same PAN. ₹15 lakh of exempt therapy plus ₹6 lakh of taxable workshops is ₹21 lakh, over the line, even though most of the income carries no tax.
2. All-exempt practices don’t have to register. Section 23(1)(a) says a person engaged exclusively in supplying services that are wholly exempt is not liable to registration, whatever the turnover. One taxable stream changes that.
3. Online clients in other states are covered by an exemption. Section 24 normally forces registration on anyone making inter-state taxable supplies, at any turnover. Notification 10/2017-Integrated Tax lifts that for service providers whose all-India aggregate turnover stays within ₹20 lakh (₹10 lakh in the four states above). A taxable online workshop for a company in another state doesn’t force you to register below the threshold.

The healthcare exemption, word for word

The exemption is entry 74 of Notification 12/2017-Central Tax (Rate), under SAC heading 9993. It exempts:

The same notification defines the terms that decide who it reaches:

• 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 a council of a recognised system of medicines, including a professional qualified to practise one under current law.
• Clinical establishment: a hospital, nursing home, clinic or other institution offering diagnosis, treatment or care for illness in a recognised system of medicines.
• Para-medics is not defined in the notification.

How that tends to apply to mental-health work:

• Clinical work by qualified clinicians, such as psychiatric treatment or clinical psychology delivered as assessment and treatment of a condition, is generally treated as exempt. RCI registration as a clinical psychologist strengthens that position.
• Counselling and coaching are a grey zone. Services framed as life coaching, wellness or personal development may not be “care for illness” at all, and would then be taxable, commonly at 18%.
• Workshops, corporate training, paid supervision, courses and writing are usually taxable even when a clinician provides them.

The exemption follows the nature of each service, not your profession as a whole. Many therapists end up with a mixed practice, which is where the invoicing choices below come from.

Which invoice to issue

What a tax invoice must show

Rule 46 of the CGST Rules lists the particulars. The ones that matter for a therapy practice:

• Your name, address and GSTIN.
• A consecutive serial number of up to sixteen characters, unique for the financial year (for example TM/26-27/041).
• The date of issue.
• The client’s name and address. For an unregistered client these are mandatory when the taxable value is ₹50,000 or more, and otherwise only if the client asks, but recording them anyway keeps your records straight. Add the client’s GSTIN for corporate or EAP clients.
• The SAC code (therapy falls under heading 9993; ask your CA for the exact code) and a description of the service.
• The taxable value, the rate, and the CGST and SGST or IGST amounts shown separately.
• For inter-state supplies, the place of supply with the state’s name.
• Your signature or digital signature.

A bill of supply under Rule 49 carries much the same supplier, number, date, client and description details, without the tax lines.

CGST and SGST, or IGST, for online clients

Under Section 12(2) of the IGST Act, the place of supply for a service to an unregistered person is the client’s location when you have their address on record, and your location otherwise. So a taxable session for a client in Pune, invoiced from Delhi with their address on file, is an inter-state supply and carries IGST. With no address on record it would be treated as supplied where you are. For a registered business client, the place of supply is their location.

A monthly invoicing routine

Indian clients often pay by UPI in round sums that don’t match a single session. A routine that keeps the paper trail clean:

1. Log each session on the day, with its status (attended, late cancellation, no-show).
2. On the first of the month, issue one invoice per client listing each session as its own dated line, plus any cancellation charge, minus any credit carried forward.
3. Number invoices in one unbroken sequence per financial year. Never reuse or skip a number; cancel and re-issue instead.
4. When a UPI payment arrives, record which invoice or sessions it covers. A ₹6,000 transfer against a ₹7,500 invoice leaves ₹1,500 open on the next one.
5. Keep therapy income and workshop or supervision income in separate columns, even below ₹20 lakh.
6. Check your trailing twelve-month turnover each quarter so the threshold never arrives as a surprise.

If you register, Section 36 of the CGST Act requires you to keep accounts and records for 72 months from the due date of the annual return for that year.

Three common situations

Two related questions come up once turnover grows. If clients pay your practice for an associate’s sessions, those fees count towards your turnover as well; the guide to hiring an associate covers that and the TDS side. Income tax is a separate matter, and many solo therapists can use the 50% presumptive scheme, explained in the section 44ADA guide.

Making the invoices

For a one-off invoice, the free therapy invoice generator makes a PDF in your browser with no account. Leave tax off and it produces a plain invoice. Turn GST on and it titles the document “Tax Invoice” and splits the tax into CGST and SGST, or shows IGST. It doesn’t produce a bill of supply.

For the monthly routine above, Therapy Manager keeps the sessions and payments together, numbers each invoice, lists every unpaid session with its date and amount, deducts carried-forward credit, and emails the PDF to your client. If you are registered it can add your GSTIN, SAC code and CGST/SGST or IGST lines, with GST on top of your fee or included in it. Check the format with your CA. Setting your fee in the first place is covered in the fees and cancellation policy guide.