Input ownership and principal supply determine GST treatment for examination printing, cheque books, Aadhaar cards and PVC cards.
Services directly relating to the conduct of examinations by educational institutions, including printing of pre-examination and post-examination items and scanning of results, fall within the exemption in Notification No. 12/2017 and are exempt from GST. For cheque-book printing, the tax treatment turns on ownership of inputs: where paper belongs to the bank, the activity is job work under heading 9988 taxable at 5%; where paper and inks are supplied by the printer, the finished cheque books are goods under heading 4907 and exempt. Aadhaar card printing on paper was treated as a composite printing service under heading 9989 taxable at 12%, while PVC card supply was classified as goods under heading 3920 taxable at 18%.
Issues: (i) Whether printing of pre-examination items, printing of post-examination items, and scanning and processing of examination results supplied to educational institutions are exempt from GST; (ii) Whether printing of cheque books where the paper is supplied by the banks is classifiable as a service and, if so, the applicable GST rate; (iii) Whether printing of cheque books where the paper and inks are borne by the applicant is classifiable as goods and whether the supply is exempt; (iv) Whether printing and supply of Aadhaar cards on paper is a composite service or a supply of goods and the applicable GST rate; (v) Whether printing and supply of PVC cards is classifiable as goods or services and the applicable GST rate.
Issue (i): Whether printing of pre-examination items, printing of post-examination items, and scanning and processing of examination results supplied to educational institutions are exempt from GST.
Analysis: Entry 66 of Notification No. 12/2017-Central Tax (Rate) grants exemption to services relating to admission to, or conduct of examination by, an educational institution. The services in question were found to be directly connected with the conduct of examinations and to be rendered to educational institutions within the meaning of the notification.
Conclusion: The supply is exempt from GST and is in favour of the assessee.
Issue (ii): Whether printing of cheque books where the paper is supplied by the banks is classifiable as a service and, if so, the applicable GST rate.
Analysis: Where the paper belongs to the banks, the activity is a treatment or process on goods belonging to another person and is therefore a job work service. Printing of cheques falling under Chapter 48 or 49 is covered by the specific rate entry for such job work services, while cheques in loose or book form are themselves exempt goods under the tariff notification.
Conclusion: The supply is classifiable as a service under heading 9988 and attracts GST at 5%, in favour of the assessee.
Issue (iii): Whether printing of cheque books where the paper and inks are borne by the applicant is classifiable as goods and whether the supply is exempt.
Analysis: Where the applicant supplies the physical inputs, the predominant supply is of the finished cheque books as goods. Cheques, loose or in book form, are classified under heading 4907 and are exempt under the relevant tariff notification.
Conclusion: The supply is classifiable under heading 4907 and is exempt from GST, in favour of the assessee.
Issue (iv): Whether printing and supply of Aadhaar cards on paper is a composite service or a supply of goods and the applicable GST rate.
Analysis: The activity involves data conversion, printing, lamination, enveloping, franking, sorting, and dispatching, all of which are naturally bundled and supplied together. The principal supply was held to be printing service, bringing the transaction under the service rate entry for printing of goods falling under Chapter 48 or 49 where only content is supplied by the recipient.
Conclusion: The supply is classifiable under heading 9989 and attracts GST at 12%, in favour of the assessee.
Issue (v): Whether printing and supply of PVC cards is classifiable as goods or services and the applicable GST rate.
Analysis: PVC cards were treated as goods because the physical inputs belonged to the applicant and the printing activity was ancillary to the principal supply of the finished plastic cards. The cards were classified under heading 3920 and subjected to the applicable goods rate.
Conclusion: The supply is classifiable under heading 3920 and attracts GST at 18%, in favour of the assessee.
Final Conclusion: The ruling answers all referred questions on classification and taxability in a manner substantially supporting the applicant's treatment of the supplies, including exemption for examination-related services and the declared rates or classifications for the other printing transactions.
Ratio Decidendi: In composite printing transactions, taxability depends on the principal supply and the ownership of physical inputs, while services directly relating to conduct of examinations by educational institutions fall within the specific exemption entry.
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AI Drafter ✕
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