Classification of printed question papers for educational exams as a service under GST Act

The Authority classified the supply of printed question papers for educational examinations as a service of printing rather than goods under the GST Act. The printing of question papers fell under Heading 9992 for Education Services, making the Applicant not liable to pay tax on this service. As the supply was considered an exempt supply, the Applicant was ruled ineligible to claim Input Tax Credit on the inputs used for printing the question papers. The ruling clarified the classification, tax liability, and Input Tax Credit eligibility for such supplies.

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Issues:
1. Determination of whether GST is applicable on the supply of printed question papers for examinations.
2. Classification of printed question papers as goods or services.
3. Applicability of Input Tax Credit on the inputs used for printing question papers.
4. Determination of SAC code for GST classification.

Analysis:
1. The Applicant sought an Advance Ruling on the applicability of GST on the supply of printed question papers for examinations. The Applicant also inquired about the eligibility for Input Tax Credit on the inputs used for the supply. The Authority admitted the Application for consideration under Sections 97(2)(a),(d)&(e) of the CGST/WBGST Acts, 2017.

2. The Applicant provided details of supplying printed question papers to various educational institutions for examinations. The question papers were printed based on the content provided by the institutions, and the Applicant did not have ownership rights over the content. The Authority analyzed whether the question papers should be classified as goods or services under the GST Act based on relevant definitions and provisions.

3. The Authority examined Section 7 of the GST Act to determine the scope of supply for goods and services. Since no specific notification was issued regarding the status of supply of question papers, the Authority concluded that the transfer of title in goods is essential for classification as goods. As the question papers were specific to the customer and not marketable commodities, the Authority classified the supply as a service of printing rather than goods.

4. The Authority further analyzed the classification under the GST Tariff-Services and determined that the printing of question papers for educational institutions falls under Heading 9992 for Education Services. The Applicant was found not liable to pay tax on the service of printing question papers related to the conduct of examinations based on relevant notifications and exemptions.

5. Considering Section 17(2) of the GST Act, the Authority ruled that since the supply of question papers for examinations was an exempt supply under the relevant notification, the Applicant was not eligible to claim Input Tax Credit on the inputs used for printing the question papers. The ruling provided clarity on the classification, tax liability, and Input Tax Credit eligibility for the supply of printed question papers for educational examinations.

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