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Issues: Whether printing of question papers for examinations conducted by educational institutions is covered by Sl. No. 66 of Notification No. 12/2017-Central Tax (Rate) and is therefore exempt supply.
Analysis: The application was admitted only on the exemption question. The service in question was printing of question papers for universities engaged in conducting examinations. The exemption entry for services supplied to an educational institution relating to admission to, or conduct of examination by, such institution was read with the clarification that Central and State Educational Boards are educational institutions for the limited purpose of conduct of examinations. On the facts, the activity of confidential printing of question papers was treated as part of the services relating to conduct of examination. The Authority therefore held that the supply fell within Sl. No. 66 of the exemption notification.
Conclusion: The service of printing question papers for conduct of examinations to educational institutions is covered by Sl. No. 66 of Notification No. 12/2017-Central Tax (Rate) and is exempt supply.
Ratio Decidendi: Printing of question papers for an educational institution, when integrally connected with the conduct of examinations, constitutes a service relating to conduct of examination and qualifies for exemption under the relevant entry.
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