Educational boards qualify for GST exemption on pre and post-examination services under Notification 12/2017-Central Tax

AAR-WB ruled that pre and post-examination services provided to educational boards and universities qualify for GST exemption under Notification 12/2017-Central Tax (Rate). The Authority held that educational boards are treated as educational institutions for examination conduct purposes, citing CBIC Circular 151/07/2021-GST. The examination process encompasses pre-examination work, actual examination, and post-examination activities. Services relating to examination conduct, including entrance examinations, are exempt from GST under serial number 66 of the notification.

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Issues Involved:

1. Whether GST exemption is available for pre and post-examination services provided to Educational Boards and Universities.

Summary:

Issue 1: GST Exemption for Pre and Post-Examination Services

The applicant provides pre and post-examination services to universities and educational boards, believing these services are exempt from GST under Sl. No. 66(b)(iv) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as amended by Notification No. 2/2018-Central Tax (Rate) dated 25.01.2018. The services include online and offline printing of pre-examination items, designing and managing web-based applications for online examinations, and post-examination services such as scanning and processing of results, and printing of mark sheets and certificates.

The applicant argues that these services fall under the category of services related to the conduct of examinations by educational institutions, which are exempt from GST. They cite several case laws and agreements with various universities to support their claim.

The Revenue concurs with the applicant's view, referencing similar rulings from other Advance Ruling Authorities.

Findings:

The Authority for Advance Ruling (AAR) examined the submissions and documents provided by the applicant, including agreements with universities. It was noted that the services provided by the applicant are integral to the conduct of examinations, which includes pre-examination, examination, and post-examination activities.

The AAR referred to the definition of 'educational institution' and relevant notifications and circulars, which clarify that services related to the conduct of examinations by educational institutions are exempt from GST.

Ruling:

The AAR ruled that the services provided by the applicant to universities in respect of the conduct of examinations (both pre and post-examination) are exempt from GST under serial number 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and West Bengal State Notification No. 1136 F.T. dated 28.06.2017.

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