Dear Student,
According to the cell theory, all living organisms are made up of cells or their products. Cells are the basic structural and functional units of cells. All living organisms exhibit certain basic properties like respiration, growth, metabolism etc. But viruses do not contain any cell organelles and nucleus but became alive when coming in contact with a living organism and performs all basic functions such as growth, replication, etc by using the host machinery. So, they are borderline between living and non-living organisms. Hence, viruses are excluded from cell theory.
Regards