GST exemption for examination-related services denied where the applicant itself conducted and assessed the ASSET test process.

ASSET services supplied to schools were held not to fall within the GST exemption for services relating to admission to, or conduct of, examinations by an educational institution. The authority found that the applicant itself set and printed the question papers, fixed the test dates, assessed the answers, and prepared the results, detailed analysis and practice material, so the examination was in substance conducted by the applicant, not the schools. The phrase "relating to" could not be stretched to cover such self-conducted activity, and decisions on mere printing or limited support services were distinguishable.

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Issues: Whether the ASSET service supplied by the applicant to schools is a service relating to conduct of examination by an educational institution and is exempt under Entry No. 66(b)(iv) of the relevant GST exemption notification.

Analysis: The exemption applies only where the service is provided to an educational institution by way of services relating to admission to, or conduct of examination by, such institution. On the record, the question papers were set and printed by the applicant, the test dates were fixed by the applicant, the answers were assessed by the applicant, and the results with detailed analysis and practice material were also prepared by the applicant. The schools had only a facilitative role and did not conduct the examination. The phrase "relating to" cannot be extended so far as to cover a service that is in substance conducted by the applicant itself, and the cited decisions concerning mere printing or limited support services were distinguishable.

Conclusion: ASSET is not a service relating to conduct of examination by the schools and the exemption is not available.

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