Printing of question papers is a taxable service when the printer performs the dominant work and supplies to non-qualifying recipients.

Printing of question papers for educational institutions is treated as a supply of services where the manuscript content is supplied by the customer and the printer's dominant role is composing, typesetting, printing, packing, transporting and delivering sealed papers. The activity is classified under Heading 9989. Exemption for services provided to educational institutions applies only when the recipient satisfies the notification's definition; where question papers are supplied to others, the exemption is unavailable and the supply is taxable at the prescribed GST rate of 12%. The ruling therefore limits the exemption to qualifying educational institutions and treats the printing arrangement as a taxable service.

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Issues: (i) Whether printing of question papers for educational institutions is to be treated as supply of goods or supply of services. (ii) Whether the supply is eligible for exemption under the notification for services provided to educational institutions, and if not, the applicable GST rate.

Issue (i): Whether printing of question papers for educational institutions is to be treated as supply of goods or supply of services.

Analysis: The manuscript content for the question papers is supplied by the education board or educational institution, while the applicant only undertakes composing, typesetting, printing, packing, transporting and delivery of sealed question papers. The printed matter is specific to the customer, the applicant does not own the content, and the service is dominated by the printing activity. On this basis, the activity is treated as a supply of service under the relevant service classification.

Conclusion: The activity is a supply of services classifiable under Heading 9989.

Issue (ii): Whether the supply is eligible for exemption under the notification for services provided to educational institutions, and if not, the applicable GST rate.

Analysis: The exemption applies only where the service is provided to an educational institution as defined in the notification. Where printing of question papers is supplied to persons other than educational institutions, the supply falls under the specified taxable entry in the rate notification and attracts GST at the prescribed rate.

Conclusion: The exemption under Sr. No. 66 of Notification No. 12/2017-Central Tax (Rate) is available only for services provided to educational institutions, and printing of question papers supplied to others is taxable at 12% GST.

Final Conclusion: The ruling treats the activity as a taxable service, while limiting exemption only to supplies made to educational institutions.

Ratio Decidendi: Where the customer supplies the manuscript content and the printer's dominant obligation is to print and deliver question papers, the transaction is a supply of service, and exemption meant for services to educational institutions is confined to recipients that satisfy the notification's definition.

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