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A medical-device manufacturer with an approximately Rs 850 crore annual portfolio (illustrative) spanning surgical instruments under HSN 9018, diagnostic devices under HSN 9018 and 9022, and X-ray apparatus under HSN 9022 must re-invoice every SKU after the 56th GST Council rate change effective 22 September 2025 — output GST drops from 18 percent to 5 percent while stainless steel inputs under HSN Chapter 72, medical-grade plastics under HSN Chapter 39, imported in-vitro diagnostic reagents under HSN Chapter 38, and packaging and sterilisation services stay at 12 or 18 percent. Ceiling-price-controlled devices under DPCO 2013 (cardiac stents, orthopaedic implants per NPPA notification) require MRP recalculation to pass the price benefit to the end-consumer; non-price-controlled devices retain the margin. The reconciliation surfaces are a SKU-wise MRP recalculation register keyed to NPPA scheduled versus non-scheduled classification, a straddle-invoice register reconciling pre-versus-post-22-September dispatches under Section 12 CGST time-of-supply rules, a Rule 89(5) monthly Form RFD-01 refund workbook against the deepened inverted-duty accumulation, and a Section 15(3) treatment matrix for post-supply MRP-transition credit notes issued to distributors on pre-cutover channel inventory.
Build a SKU master keyed to HSN code (9018, 9019, 9020, 9021, or 9022), NPPA scheduled/non-scheduled flag, pre-22-September MRP, ex-tax ceiling value (for scheduled SKUs), and post-22-September recomputed MRP. Run the MRP recalculation on scheduled SKUs mechanically — post-cutover MRP equals ex-tax ceiling plus 5 percent (versus pre-cutover ex-tax ceiling plus 18 percent). Extract the invoice register split by date of removal, date of invoice, date of e-way bill IRN, and date of e-invoice IRN; classify each invoice as pre-cutover 18 percent or post-cutover 5 percent by the earlier of invoice date and payment receipt date per Section 12 CGST. Compute the inverted-duty position monthly — output GST at 5 percent on eligible turnover minus input GST at 12 to 18 percent on stainless steel, medical-grade plastics, IVD reagents, packaging (HSN 3923/4819), and sterilisation services — and file Form GST RFD-01 under the Rule 89(5) amended formula with input services and capital goods excluded from Net ITC. Maintain a Section 15(3) matrix by distributor by SKU flagging whether any MRP-transition credit note is pre-cutover-agreement-linked (Section 15(3) tax-adjustment eligible) or secondary discount (Section 34 commercial-only).
SKU master with HSN heading (9018/9019/9020/9021/9022), NPPA scheduled flag, DPCO Schedule I reference, ceiling ex-tax value, pre-cutover MRP, post-cutover MRP; input master with HSN chapter (72 stainless steel, 39 medical-grade plastic, 38 IVD reagent, 4819 corrugated carton, 3923 polymer pouch) and applicable GST rate; sterilisation service vendor register with vendor GSTIN and HSN 9987; e-invoice IRN and e-way bill number feed keyed by date of removal, date of invoice, and date of payment receipt; Section 12 CGST cutover flag on every invoice; Rule 89(5) refund workbook with Net ITC segregation (goods eligible, services and capital goods excluded per Notification 14/2022 and Union of India v. VKC Footsteps); distributor master with pre-22-September channel inventory tally by SKU and lot; Section 15(3) treatment matrix per distributor per credit-note event; Circular 92/11/2019-GST reference on secondary discounts.
A monthly medical-device rate-transition reconciliation pack: SKU-wise MRP recalculation register per NPPA scheduled versus non-scheduled classification with pre- and post-cutover MRP columns; straddle-invoice register reconciling every dispatch across 21-22 September 2025 by time-of-supply anchor and GST rate applied; monthly Form GST RFD-01 refund draft under Rule 89(5) with Net ITC segregation and the Notification 14/2022 amended formula; per-distributor Section 15(3) credit-note matrix with tax-adjustment eligibility flag; and a distributor channel-inventory reconciliation on pre-22-September stock that ties the manufacturer's credit-note liability to the distributor's GSTR-2B reversal. Match rate improvement on the rate-transition reconciliation chain supports a clean audit trail against Section 65 GST audit on the transition period and expedited RFD-01 processing per the GST Council FAQ Q25 pledge.
The 56th GST Council meeting recommendations dated 3 September 2025, notified effective 22 September 2025, moved every medical instrument and apparatus classifiable under HSN 9018 through 9022 from the 18 percent GST slab to the 5 percent slab. For an integrated medical-device manufacturer running a broad portfolio across surgical instruments (HSN 9018), diagnostic and imaging devices (HSN 9018 and 9022), and X-ray apparatus (HSN 9022), the rate change is not a single-line invoice update — it is a re-invoicing programme spanning SKU-wise MRP recalculation for NPPA scheduled devices under DPCO 2013, a straddle-invoice reconciliation across the 21-22 September 2025 cutover under Section 12 CGST time-of-supply rules, a substantially deepened Rule 89(5) inverted-duty refund cycle against 18 percent stainless steel and medical-grade plastic inputs, and a Section 15(3) treatment matrix for distributor-side MRP-transition credit notes. This is medical device HSN 9018 9022 GST 18 to 5 percent 22 September 2025 at operating scale, and the discipline that separates a manufacturer whose transition period passes clean audit from one that spends the following year defending misclassified straddle invoices is a per-SKU rate-transition reconciliation platform.
Quick reference
| Aspect | Detail |
|---|---|
| Rate change notification | 56th GST Council meeting recommendations dated 3 September 2025 |
| Effective date | 22 September 2025 (prospective) |
| Old rate | 18 percent CGST plus SGST |
| New rate | 5 percent CGST plus SGST |
| HSN coverage | 9018, 9019, 9020, 9021, 9022 — Chapter 90 medical instruments and apparatus |
| HSN 9018 scope | Medical, surgical, dental, veterinary instruments (syringes, ECG, ultrasonic, MRI) |
| HSN 9021 scope | Orthopaedic appliances, cardiac stents, hip and knee implants, hearing aids |
| HSN 9022 scope | X-ray apparatus, radiography, radiotherapy, X-ray tubes |
| Time-of-supply anchor | Section 12 CGST — earlier of invoice date or payment receipt date |
| Ceiling-price framework | DPCO 2013 read with NPPA scheduled device notifications |
| Inverted-duty refund | Section 54(3) CGST filed monthly on Form GST RFD-01 |
| Refund formula | Rule 89(5) CGST Rules, as amended by Notification 14/2022-Central Tax |
| Amendment date | 5 July 2022 (prospective — applications on or after use amended formula) |
| Supreme Court anchor | Union of India v. VKC Footsteps (2021) 10 SCC 674 — services and capital goods excluded from Net ITC |
| Post-supply discount | Section 15(3) CGST read with Circular 92/11/2019-GST |
| GST Council FAQ | Q10, Q25, Q51 acknowledge deepened inversion and pledge expedited RFD-01 |
The reconciliation in one paragraph
The 22 September 2025 cutover requires the medical-device manufacturer to switch every finished-goods SKU under HSN 9018, 9019, 9020, 9021, and 9022 from a pre-cutover 18 percent output GST regime to a post-cutover 5 percent output GST regime, while the input tax base — stainless steel under HSN Chapter 72 at 18 percent, medical-grade plastics under HSN Chapter 39 at 18 percent, imported in-vitro diagnostic reagents under HSN Chapter 38 at 12 or 18 percent, corrugated and polymer packaging at 18 percent, and sterilisation service inputs at 18 percent — is untouched by the rate change. The reconciliation cascade runs across four surfaces. First, a SKU-wise MRP recalculation register keyed to NPPA scheduled versus non-scheduled classification under DPCO 2013 — scheduled SKUs must pass the 13 percentage-point price benefit to the end-consumer via revised MRP on the pack, while non-scheduled SKUs may retain the margin uplift. Second, a straddle-invoice register that reconciles every dispatch across the 21-22 September boundary by time-of-supply anchor under Section 12 CGST — date of invoice or date of payment receipt, whichever is earlier, determines the applicable rate. Third, a Rule 89(5) monthly Form RFD-01 refund workbook that computes the substantially deepened inverted-duty accumulation under the Notification 14/2022-amended formula, with input services and capital goods excluded from the Net ITC numerator per Union of India v. VKC Footsteps. Fourth, a Section 15(3) treatment matrix for distributor-side MRP-transition credit notes on pre-22-September channel inventory — where the credit-note obligation was contemplated in a pre-cutover distribution agreement, the manufacturer reduces output tax and the distributor reverses ITC; where no such linkage exists, Circular 92/11/2019-GST governs the treatment as a secondary discount outside Section 15(3).
What the scenario looks like in India
The medical-device sub-cluster within Indian pharma is dominated by a mix of integrated pharma groups with device divisions, pure-play device manufacturers, and public-sector device suppliers. Piramal Pharma runs a medical-device division alongside its formulation business — surgical instruments and diagnostic devices under HSN 9018 sit in that division’s SKU master alongside X-ray-adjacent apparatus under HSN 9022. Poly Medicure is a pure-play device manufacturer with a portfolio centred on medical consumables (catheters, cannulae, syringes) predominantly classified under HSN 9018. HLL Lifecare is the Central Public Sector Enterprise under the Ministry of Health & Family Welfare that supplies contraceptives, diagnostic kits, and hospital consumables across the public-health procurement channel. Wockhardt operates a diversified pharma-plus-device footprint with the Aurangabad and Ankleshwar clusters as manufacturing anchors. The illustrative persona for this article is Piramal Pharma’s medical-device division running an approximately Rs 850 crore annual portfolio (illustrative) split across surgical instruments (HSN 9018), diagnostic and imaging devices (HSN 9018 and 9022), and X-ray apparatus (HSN 9022) — a scale at which the SKU count runs into the low thousands and every SKU must move rate on 22 September 2025.
The DPCO 2013 ceiling framework overlays a further split within the HSN 9018 to 9022 population. NPPA notifies ceiling prices for scheduled medical devices — cardiac stents (bare-metal and drug-eluting), orthopaedic knee implants, and specified consumables are the principal scheduled categories. A manufacturer’s SKU master must carry the NPPA scheduled flag on every device, and the post-22-September MRP recalculation is mechanical for scheduled SKUs — the ceiling price is fixed ex-tax, and MRP equals ceiling plus applicable GST. Non-scheduled devices are outside the ceiling framework, and the manufacturer’s commercial policy determines whether the 13 percentage-point rate reduction is passed through as a lower MRP or retained as an incremental margin.
The regulatory overlay — Section 12, Section 54(3), Rule 89(5), Section 15(3)
Four regulatory anchors govern the rate-transition reconciliation and each maps to a specific surface.
Section 12 of the CGST Act 2017 defines the time of supply of goods as the earlier of the date of issue of invoice by the supplier under Section 31 or the date on which the supplier receives payment. Section 31 requires the invoice to be issued before or at the time of removal of goods for supply. The rate applicable to the supply is the rate in force at the time of supply so determined. A device removed from the manufacturer’s warehouse on 20 September 2025 and invoiced the same date is a pre-cutover supply — time of supply is 20 September and the rate is 18 percent, even if physical delivery to the distributor completes on 24 September. A device removed and invoiced on 23 September 2025 is a post-cutover supply at 5 percent. Advance receipts collected on or before 21 September against dispatches on or after 22 September are the residual sub-case that requires a credit-note true-up on the advance receipt. The e-way bill IRN and the e-invoice IRN, both timestamped on the CBIC portal, constitute the authoritative audit trail of the time-of-supply anchor.
Section 54(3) of the CGST Act 2017 permits a registered person to claim a refund of unutilised input tax credit where the credit has accumulated on account of the rate of tax on inputs being higher than the rate of tax on output supplies. The Supreme Court in Union of India v. VKC Footsteps India Pvt Ltd (2021) 10 SCC 674 upheld the statutory framework and confirmed that the refund is confined to unutilised credit on inputs — input services and capital goods are excluded. Rule 89(5) of the CGST Rules 2017, as amended by Notification 14/2022-Central Tax dated 5 July 2022, provides the operational formula. Maximum Refund Amount = (Turnover of inverted-rated supply of goods and services × Net ITC / Adjusted Total Turnover) minus (Tax payable on such inverted-rated supply × Net ITC / ITC availed on inputs and input services). Net ITC excludes input services and capital goods. The amendment applies prospectively — refund applications filed on or after 5 July 2022 use the amended formula. For a medical-device manufacturer post 22 September 2025, the inversion arises because HSN 9018 to 9022 output moves to 5 percent while stainless steel inputs (HSN Chapter 72), medical-grade plastic inputs (HSN Chapter 39), IVD reagent inputs (HSN Chapter 38 at 12 or 18 percent), packaging inputs (HSN 4819 at 18 percent, HSN 3923 at 18 percent) all remain at their existing rates. The refund is filed monthly on Form GST RFD-01, and the GST Council FAQ Q25 pledges expedited processing for the medical-device sector post-cutover. The same Rule 89(5) mechanic operating in Agro Processing on packaged milk against packaging inputs is walked through in dairy inverted-duty refund under Rule 89(5) post GST 2.0; the pharma-specific formulation walk-through sits at Rule 89(5) inverted-duty refund pharma formulations.
DPCO 2013 read with NPPA scheduled-device notifications governs the ceiling-price framework. Cardiac stents (bare-metal and drug-eluting), orthopaedic knee implants, and specified consumables sit in NPPA’s scheduled list. The ceiling price is fixed exclusive of local taxes; the MRP printed on the pack is inclusive of applicable GST. A change in GST rate requires MRP recalculation within the ceiling framework and re-declaration of MRP on the pack. Para 20 of DPCO 2013 provides the recovery mechanism for overcharging above the recomputed ceiling — a manufacturer that continues to print or invoice at the pre-cutover MRP on a scheduled device post 22 September attracts DPCO recovery in addition to any GST-side implications.
Section 15(3) of the CGST Act 2017 governs the tax treatment of post-supply discounts. A discount is excluded from transaction value only if given before or at the time of supply and duly recorded on the invoice, or if given after supply under an agreement entered into at or before the time of supply that is linked to relevant invoices and against which the recipient reverses the proportionate input tax credit. Circular 92/11/2019-GST provides the CBIC clarification on secondary discounts. For a manufacturer issuing an MRP-transition credit note to a distributor on pre-22-September channel inventory, the Section 15(3)(b) linkage test is decisive — if the distribution agreement pre-dating 22 September contemplates the rate-change adjustment, the credit note carries a proportionate GST reduction and the distributor reverses ITC accordingly; otherwise the credit note is a commercial secondary discount outside Section 15(3) and no GST adjustment attaches.
A worked example — Piramal Pharma medical-device division at 22-September cutover
Illustrative — Piramal Pharma’s actual medical-device portfolio scale and SKU-level MRP have not been publicly disclosed at the granularity used in this walk-through. The figures below represent the operating pattern of a diversified medical-device division of the approximate scale a listed Indian pharma group with a device business runs. Cross-verify against your own MRP declaration and RFD-01 draft before any operational or filing action.
The medical-device division running an approximately Rs 850 crore annual portfolio splits its SKU base into three families. Family A — surgical instruments and orthopaedic implants under HSN 9018 and 9021 — accounts for approximately Rs 340 crore annual, with cardiac stents and knee implants as the NPPA-scheduled sub-set (approximately 40 percent of Family A revenue). Family B — diagnostic devices and imaging apparatus under HSN 9018 and 9022 — accounts for approximately Rs 310 crore, largely non-scheduled. Family C — X-ray apparatus, X-ray tubes, and radiotherapy apparatus under HSN 9022 — accounts for approximately Rs 200 crore, non-scheduled.
MRP recalculation on a representative NPPA-scheduled drug-eluting cardiac stent SKU with ex-tax ceiling of Rs 30,000: pre-22-September MRP was Rs 30,000 plus 18 percent = Rs 35,400; post-22-September MRP is Rs 30,000 plus 5 percent = Rs 31,500. The manufacturer re-declares MRP on the pack and issues a distributor notification with the revised price list. On a representative non-scheduled X-ray tube SKU with pre-cutover MRP of Rs 118,000 (containing an implicit Rs 100,000 ex-tax plus Rs 18,000 GST): the manufacturer’s commercial policy may either drop MRP to Rs 105,000 (Rs 100,000 plus 5 percent GST — passing the benefit) or hold MRP at Rs 118,000 (implicit ex-tax rises to Rs 112,381, retaining Rs 12,381 as incremental margin per unit). Both are permissible under the non-scheduled regime; the reconciliation surface is the SKU master’s post-cutover MRP field and the corresponding invoicing configuration.
Straddle-invoice illustration: on 20 September 2025 the manufacturer removes 400 units of an HSN 9018 surgical instrument SKU at an ex-tax value of Rs 8,500 per unit and invoices the same date to a Mumbai distributor. Time of supply is 20 September; the invoice attracts 18 percent CGST plus SGST — invoice value is Rs 34.0 lakh ex-tax plus Rs 6.12 lakh GST = Rs 40.12 lakh. On 23 September, the manufacturer removes 350 units of the same SKU at the same ex-tax value and invoices on 23 September to a Delhi distributor. Time of supply is 23 September; the invoice attracts 5 percent CGST plus SGST — invoice value is Rs 29.75 lakh ex-tax plus Rs 1.4875 lakh GST = Rs 31.2375 lakh. A third dispatch: on 21 September the manufacturer receives an advance payment of Rs 15 lakh from a Bengaluru distributor against an order to be dispatched on 25 September. Time of supply on the advance is 21 September; the manufacturer issues a receipt voucher at 18 percent. On 25 September the dispatch is invoiced at 5 percent and a credit note is issued adjusting the pre-cutover advance-receipt-voucher to the post-cutover invoice rate.
The monthly inverted-duty position for October 2025 (first full post-cutover month): output supply of medical devices under HSN 9018 to 9022 at approximately Rs 71 crore attracts Rs 3.55 crore output GST at 5 percent. Input GST for the same month: stainless steel purchases at approximately Rs 4.2 crore GST (HSN Chapter 72 at 18 percent), medical-grade plastic purchases at approximately Rs 2.8 crore GST (HSN Chapter 39 at 18 percent), imported IVD reagent purchases at approximately Rs 1.1 crore GST (HSN Chapter 38 at 12 to 18 percent blended), packaging purchases at approximately Rs 0.9 crore GST (HSN 4819 and 3923 at 18 percent), sterilisation service purchases at approximately Rs 0.7 crore GST (18 percent). Total input GST: approximately Rs 9.7 crore, of which the goods component (eligible for Rule 89(5) Net ITC) is approximately Rs 9.0 crore and the sterilisation service component (ineligible per Notification 14/2022 and VKC Footsteps) is approximately Rs 0.7 crore. Accumulated inverted-duty ITC post output-tax offset is approximately Rs 5.45 crore for the month. The manufacturer files Form GST RFD-01 for October 2025 in November against this accumulation, computed under the Notification 14/2022-amended Rule 89(5) formula with the goods component in the Net ITC numerator.
Common reconciliation breakages
Five breakages recur across medical-device manufacturers navigating the 22 September 2025 rate cutover, and each maps to a specific control failure.
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Straddle invoice classified by physical delivery date rather than time-of-supply anchor. Warehouses that key invoice rate to the transporter’s proof-of-delivery date (rather than to the earlier of invoice date or payment receipt date per Section 12 CGST) will misclassify a dispatch removed on 20 September but delivered on 24 September as a post-cutover 5 percent supply. The distributor’s GSTR-2B then reflects the invoice at 5 percent while the manufacturer’s e-invoice IRN was issued at 18 percent — an unmatched line at both ends.
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NPPA scheduled flag missing on SKU master. Manufacturers whose SKU master does not carry the NPPA scheduled flag will apply a uniform post-cutover MRP policy across the entire HSN 9018 to 9022 population. Non-scheduled SKUs are then unnecessarily discounted, or scheduled SKUs are held at pre-cutover MRP in breach of DPCO Para 20 — attracting NPPA recovery independent of any GST-side implication.
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Rule 89(5) Net ITC inflated by sterilisation service credit. Ethylene oxide and gamma-ray sterilisation contract services at 18 percent GST are input services under Notification 14/2022 and are excluded from Net ITC in the Rule 89(5) refund formula. Refund workbooks that include sterilisation service credit in Net ITC overstate the maximum refund. The proper officer’s audit will disallow the excess and expose the manufacturer to Section 74 penalty.
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Advance receipt residuals uncredited across cutover. Advance payments collected pre-22-September against dispatches post-22-September require a credit-note true-up on the receipt voucher issued at 18 percent. Manufacturers that omit the credit-note step carry an 18 percent liability on the receipt voucher and a 5 percent liability on the corresponding invoice — double reporting at the manufacturer end and a distributor ITC mismatch.
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MRP-transition distributor credit note treated uniformly. Blanket treatment of MRP-transition credit notes as Section 15(3) tax-adjustment eligible (regardless of pre-cutover agreement linkage) will over-reduce the manufacturer’s output tax and expose the distributor to an ITC-reversal shortfall on GSTR-3B. The correct treatment requires a per-distributor Section 15(3) matrix distinguishing pre-cutover-agreement-linked credits (tax-adjustment eligible) from secondary-discount credits (Section 34 commercial-only) per Circular 92/11/2019-GST. The reconciliation playbook monthly close framework treats the credit-note treatment matrix as a standing month-end control.
How a reconciliation platform handles this
A purpose-built pharma and medical-device reconciliation platform ingests the SKU master with HSN heading and NPPA scheduled flag, the e-invoice and e-way bill feed with removal, invoice, and payment-receipt timestamps, the input GST register split by HSN chapter, the sterilisation service vendor ledger, and the distributor channel-inventory tally — and produces a per-SKU rate-transition reconciliation view that closes the loop from time-of-supply classification through inverted-duty refund draft through Section 15(3) credit-note treatment. The platform runs the mechanical MRP recalculation on every NPPA-scheduled SKU, applies the Section 12 CGST rule on every straddle invoice, computes the Rule 89(5) refund draft under the Notification 14/2022-amended formula with Net ITC correctly segregated between eligible goods and ineligible services, and generates the per-distributor Section 15(3) credit-note matrix with pre-cutover-agreement-linkage flag. Match rate improvement of 51 to 88 percent on the rate-transition reconciliation chain, combined with an ISO 27001:2022 posture and DPDP Act 2023 aligned data handling, is what makes the platform an infrastructure investment for an Indian medical-device manufacturer navigating the 22 September 2025 cutover rather than a spreadsheet substitute. See pharma reconciliation software India for the commercial pillar and GST reconciliation software for the cross-cluster GST reconciliation anchor.
Cross-cluster bridges and where to read next
The 22 September 2025 rate transition sits at the core of the Pharma Wave A cluster. For the full 56th GST Council rate-change context spanning drugs and medical devices, read the GST Council 56 pharma drugs medical devices 5 percent transition sibling. For the inventory GST rate switch mechanics on 22 September 2025, the pharma inventory GST rate switch reconciliation walk-through covers the closing-stock and opening-stock rate-transition tally. The straddle-invoice cascade across the cutover boundary is unpacked in straddle invoice pharma pre-post-22-Sept 2025 reconciliation. For the same Rule 89(5) inverted-duty refund mechanic operating on packaged milk in Agro Processing, read dairy inverted-duty refund under Rule 89(5) post GST 2.0. The month-end control that anchors every post-cutover close is described in the reconciliation playbook monthly close framework. The commercial pillar for the entire pharma sub-cluster is pharma reconciliation software India; the broader authority is reconciliation software India.
The five FAQs below address the operational questions Indian medical-device manufacturers’ finance and tax teams ask most often on the HSN 9018 to 9022 rate-transition reconciliation.
Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →
- ▸ 56th GST Council meeting recommendations dated 3 September 2025, effective 22 September 2025 — Landmark rate rationalisation moving all medical instruments and apparatus classifiable under HSN 9018 through 9022 from 18 percent to 5 percent CGST plus SGST. GST Council FAQ Q10, Q25, and Q51 explicitly acknowledge the deepening of the inverted duty structure created by the rate change and pledge expedited processing of Section 54(3) inverted-duty refunds. Rate change is prospective — supply of devices on or after 22 September 2025 attracts 5 percent; supply on or before 21 September 2025 continues to attract 18 percent.
- ▸ HSN Chapter 90 headings 9018, 9019, 9020, 9021, 9022 — Customs Tariff Act 1975 read with CGST Rate Notifications — HSN 9018 covers instruments and appliances used in medical, surgical, dental, or veterinary sciences (including syringes, needles, catheters, cannulae, ECG apparatus, ultrasonic scanning apparatus, magnetic resonance imaging apparatus). HSN 9019 covers mechano-therapy appliances, massage apparatus, psychological aptitude-testing apparatus, ozone therapy apparatus, oxygen therapy apparatus, aerosol therapy apparatus, artificial respiration apparatus. HSN 9020 covers other breathing appliances and gas masks. HSN 9021 covers orthopaedic appliances (including crutches, surgical belts, and trusses), splints and other fracture appliances, artificial parts of the body (including cardiac stents, hip and knee implants), hearing aids. HSN 9022 covers apparatus based on the use of X-rays or of alpha, beta or gamma radiations (including radiography or radiotherapy apparatus, X-ray tubes, and other X-ray generators).
- ▸ Section 54(3) and Rule 89(5) CGST Act and Rules 2017, as amended by Notification 14/2022-Central Tax dated 5 July 2022 — Refund of unutilised input tax credit accumulated on account of the inverted duty structure. Maximum Refund Amount = (Turnover of inverted-rated supply of goods and services × Net ITC / Adjusted Total Turnover) − (Tax payable on such inverted-rated supply × Net ITC / ITC availed on inputs and input services). Net ITC excludes input services and capital goods (upheld by the Supreme Court in Union of India v. VKC Footsteps India Pvt Ltd (2021) 10 SCC 674). Applications filed on or after 5 July 2022 use the amended formula; prior applications use the pre-amendment formula. Refund is filed monthly on Form GST RFD-01.
- ▸ Drugs (Prices Control) Order 2013 read with NPPA notifications — The National Pharmaceutical Pricing Authority (NPPA), under the Department of Pharmaceuticals, notifies ceiling prices for scheduled formulations and scheduled medical devices under DPCO 2013. Cardiac stents (bare-metal and drug-eluting), orthopaedic knee implants, and specified consumables are notified as scheduled medical devices; the ceiling price is fixed exclusive of local taxes, and the retail MRP printed on the pack is inclusive of applicable GST. A change in the GST rate on a scheduled device requires the manufacturer to recompute and re-declare MRP within the ceiling framework. Para 20 of DPCO 2013 provides the recovery mechanism for overcharging above the ceiling.
- ▸ Section 15 and Section 15(2) of the CGST Act 2017 — Section 15 defines the value of a taxable supply as the transaction price where supplier and recipient are unrelated and price is the sole consideration. Section 15(2) enumerates inclusions to transaction value. Section 15(3) governs discounts — a discount is excluded from transaction value only if given before or at the time of supply and duly recorded in the invoice, or if given after supply under an agreement entered into at or before the time of supply that is linked to relevant invoices and against which the recipient reverses the ITC. Post-supply MRP-transition discounts on inventory held by distributors at the 22 September 2025 cutover are governed by Section 15(3) read with Circular 92/11/2019-GST on secondary discounts.