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        Case ID :

        2022 (7) TMI 501 - AAR - GST

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        Educational institutions' printing services for exam materials and result processing qualify as exempt supplies under GST Serial Number 66 AAR-AP ruled that printing services for examination materials (question papers, OMR sheets, answer booklets) and post-examination items (mark cards, grade ...
                        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

                            Educational institutions' printing services for exam materials and result processing qualify as exempt supplies under GST Serial Number 66

                            AAR-AP ruled that printing services for examination materials (question papers, OMR sheets, answer booklets) and post-examination items (mark cards, grade cards, certificates) provided to educational institutions qualify as exempt supplies under GST. The services of scanning and processing examination results also fall under the same exemption. The ruling applies to supplies made to universities and educational boards including secondary and higher secondary examination boards, as these institutions provide education leading to recognized qualifications. All such supplies are exempt under Serial Number 66 of Notification No.12/2017-CGST[Rate].




                            Issues Involved:
                            1. Classification of products and applicability of notification for considering the tax rate.
                            2. Whether printing of pre-examination items is an exempted supply of service.
                            3. Whether printing of post-examination items is an exempted supply of service.
                            4. Whether scanning and processing of examination results is an exempted supply of service.

                            Detailed Analysis:

                            1. Classification of Products and Applicability of Notification for Considering the Tax Rate:
                            The applicant, M/s. Universal Print Systems, is engaged in printing various items, including high-end security printing products. They approached the Authority for Advance Ruling to seek clarification on the classification of their products and the applicable tax rate under the GST regime. The relevant notification under consideration is Notification No.12/2017-CGST[Rate] dated 28-6-2017, which outlines exemptions for certain services provided to educational institutions.

                            2. Whether Printing of Pre-Examination Items is an Exempted Supply of Service:
                            The applicant provides printing services for pre-examination items like question papers, OMR sheets, and answer booklets, which are used by educational boards for conducting examinations. The applicant argued that these services should be exempt from GST under Serial Number 66 of Notification No.12/2017-CGST[Rate], which exempts services related to the conduct of examinations by educational institutions. The Authority concurred with the applicant’s interpretation, affirming that these services are indeed exempt from GST.

                            3. Whether Printing of Post-Examination Items is an Exempted Supply of Service:
                            The applicant also provides printing services for post-examination items such as marks cards, grade cards, and certificates. These items are used by educational boards to communicate examination results to students. The applicant contended that these services should also be exempt under the same notification, as they are related to the conduct of examinations. The Authority agreed, ruling that printing of post-examination items is exempt from GST.

                            4. Whether Scanning and Processing of Examination Results is an Exempted Supply of Service:
                            The applicant offers services for scanning and processing examination results. They argued that these services are integral to the conduct of examinations and should be exempt under the aforementioned notification. The Authority examined the relevant provisions and concurred with the applicant’s view, ruling that scanning and processing of examination results are exempt from GST.

                            Conclusion:
                            The Authority for Advance Ruling ruled affirmatively on all three queries raised by the applicant. The printing of pre-examination items, post-examination items, and the scanning and processing of examination results are all considered exempt supplies of service under Serial Number 66 of Notification No.12/2017-CGST[Rate] dated 28-6-2017, as amended. This exemption applies specifically to services related to the conduct of examinations provided to educational institutions as defined in the notification.
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                            ActsIncome Tax
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