Printing Question Papers Classified as a Service under GST

IN RE : MANASWI DAS

IN RE : MANASWI DAS - 2020 (42) G. S. T. L. 466 (A. A. R. - GST - U. P.) Issues:
1. Classification of activity of printing question papers as supply of goods or services under GST.
2. Determination of GST applicability, rate, and HSN/SAC code for printing question papers.

Issue 1: Classification of activity of printing question papers

The applicant, engaged in confidential printing and supply services, sought clarification on whether printing question papers for educational institutions constitutes supply of goods or services. The applicant detailed their services, including printing pre and post-examination items and scanning and processing exam results for educational boards. The applicant argued that since they only provide printing services and do not own the content of question papers, their supply should be classified as a service under Heading 9989 of the classification of services. The Authority considered the applicant's submissions and noted that the usage rights of the manuscript material belong to the educational institutions, making printing the principal supply, thus classifying it as a service.

Issue 2: Determination of GST applicability, rate, and HSN/SAC code

Regarding the GST applicability and rate for printing question papers, the Authority analyzed the definition of 'Educational Institutions' under Notification No. 12/2017-Central Tax (Rate). It was observed that the benefit of GST exemption is applicable only when the service is provided to an educational institution. For services provided to entities other than educational institutions, the GST rate would be 12% (CGST 6% + SGST 6% or IGST 12%) under Sr. No. 27(i) of Notification No. 11/2017-Central Tax (Rate). Therefore, the Authority ruled that the printing of question papers by the applicant is classified as a service under Heading 9989, and the GST rate applicable would be 12% for services provided to entities other than educational institutions.

This judgment by the Authority for Advance Ruling, Uttar Pradesh, clarified the classification of printing question papers as a service under GST and determined the applicable GST rate based on the recipient of the service.