Question-paper printing is treated as a composite service, with educational exemption limited to qualifying recipients only.
Confidential printing of question papers, where educational institutions supply the content and the printer performs composing, typesetting, printing, packing, transport and delivery of sealed papers, is treated as a composite supply with printing as the principal supply. The printed papers have no independent marketability in the open market, so the activity is classifiable as a service under Heading 9989 rather than as goods. The educational-institution exemption applies only when the service is supplied to a recipient covered by the notification; printing for other recipients does not qualify and attracts GST at 12%.
Issues: (i) Whether confidential printing of question papers on behalf of educational institutions is a supply of goods or a supply of services and the proper classification of such activity. (ii) Whether exemption under the notification governing services to educational institutions is available, and if not, the applicable rate of tax.
Issue (i): Whether confidential printing of question papers on behalf of educational institutions is a supply of goods or a supply of services and the proper classification of such activity.
Analysis: The content of the question papers was supplied by the educational boards or institutions, while the applicant only performed composing, typesetting, printing, packing, transport and delivery of sealed papers. The printed papers were specific to the customer, were not pre-printed goods, and had no marketability or independent utility in the open market. The printing element constituted the dominant element of the transaction, making the supply a composite supply in which printing was the principal supply and the recipient's content remained the core input.
Conclusion: The activity is supply of services and is classifiable under Heading 9989.
Issue (ii): Whether exemption under the notification governing services to educational institutions is available, and if not, the applicable rate of tax.
Analysis: The exemption applies only where the service is provided to an educational institution as defined in the notification. Printing of question papers supplied to entities other than educational institutions does not qualify for that exemption. Such supply falls under the rate entry for printing services and is taxable at the prescribed rate.
Conclusion: The exemption is available only when the service is provided to an educational institution, and printing services supplied to others attract GST at 12%.
Final Conclusion: The ruling treats question-paper printing as a taxable service rather than goods, while limiting the educational-institution exemption to qualifying recipients only.
Ratio Decidendi: Where the recipient supplies the content and the printer merely performs the physical printing and allied delivery functions, the principal supply is printing service, not goods; exemption provisions are confined to the class of recipients expressly covered by the notification.
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