Supply of question paper along with printing services to educational institution is exempted from GST

The AAR, Telangana, in the matter of IN RE: M/S. Y.S. HITECH SECURE PRINT PRIVATE LIMITED - 2023 (6) TMI 984 - AUTHORITY FOR ADVANCE RULING, TELANGANA  ruled that, the supply of printing services provided to educational institutions for question papers, OMR sheets, answer sheets, marks card etc. using his own paper and ink is a composite supply and are exempted from GST as per Sr. No. 66(b)(iv) of Notification No. 12/2017-Central Tax (Rate) dated June 28, 2017(“the Service Exemption Notification”).

Facts:

M/s. YS Hitech Secure Print Pvt. Ltd. (“the Applicant”) inter aliaengaged in the printing of products like question papers for conducting examinations, barcode, OMR answer booklets, OMR sheets, Certificates, Marks Memo, MICR cheque books for educational institutions.

The Applicant submitted that the products are designed and printed as per the requirements of customer, in other words the products cannot be delivered to any other person since the printing is combined with security features in many products like cheque books so as to prevent misuse by forgery/replication by unauthorized persons.

The Applicant filed an application for advance ruling seeking clarification regarding the applicability of the exemption on printing services provided by them.

Issue:

Whether supply of question papers to educational institutes would be treated as supply of goods or service, if treated as supply of service then, whether it would be exempt from GST being services provided to an educational institution?

Held:
The AAR, Telangana, in IN RE: M/S. Y.S. HITECH SECURE PRINT PRIVATE LIMITED - 2023 (6) TMI 984 - AUTHORITY FOR ADVANCE RULING, TELANGANA   ruled as under:

• Observed that, printed question papers are not covered under any of the Custom Tariff Headings from 4901 to 4910, therefore it will be classifiable under Heading 4911 which covers “Other printed matter, including printed pictures and photographs”, accordingly the GST @ 12% would be leviable.
• Noted that, exemption is given only to services not to goods and the supplies printing of test question papers, OMR sheets, Certificates, Marks Memo, MICR cheque books etc. using his own paper and ink.
• However, in the present case, the services of printing papers/question papers, OMR sheets, Certificates, Marks Memo, MICR cheque books etc. provided to educational institutions is a composite supply in which the printing service is the principal supply, which makes HSN classification of the whole supply to classified as printing services which falls under SAC 9989.
• Held that, the principal supply makes the supply exempt from payment of GST as per Sr. No. 66(b)(iv) of the Service Exemption Notification.

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