Educational printing services including exam papers and certificates qualify for GST exemption under notification 12/2017

AAR Uttar Pradesh ruled that printing of examination papers, OMR sheets, answer sheets, mark sheets, certificates and related documents for educational institutions constitutes supply of services, not goods. The printing activity gives essential character to the product per GST circular 11/11/2017. Such services qualify for GST exemption under serial no. 66 of Notification 12/2017-CT (Rate) as they relate to admission or conduct of examinations by educational institutions, with no restriction to higher secondary level only.

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Issues Involved:
1. Classification of the activity of printing as supply of goods or services.
2. Applicability of exemption under Notification 12/2017-CT (Rate) for services related to the conduct of examinations by educational institutions.
3. Determination of tax liability if classified as supply of services or goods.

Summary:

Issue 1: Classification of Activity as Supply of Goods or Services
The applicant, engaged in security printing for educational institutions, sought clarification on whether their printing activities (Question Papers, OMR Sheets, Answer Sheets, Marks Sheets, Certificates) constitute supply of goods or services. The Authority referred to Circular No. 11/11/2017-GST, which clarifies that if the printing activity gives the essential character to the product, it is classified as a supply of service. Since the applicant's printing activities provide the essential character to the printed products, they are classified as supply of services.

Issue 2: Applicability of Exemption under Notification 12/2017-CT (Rate)
The applicant inquired if their services qualify for exemption under Sr. No. 66 of Notification No. 12/2017-CT (Rate) as amended. The Authority confirmed that services related to the admission to, or conduct of examinations by educational institutions are exempt from GST. Since the applicant's services (printing of Question Papers, OMR Sheets, Answer Sheets, Marks Sheets, Certificates) are related to the conduct of examinations, they qualify for the exemption under Sr. No. 66 of Notification No. 12/2017-CT (Rate).

Issue 3: Determination of Tax Liability
The applicant also sought clarification on whether their activities should be treated as exempted goods under serial no. 119 of the exempted list or taxable under schedule I at serial no. 201. Given that the activities are classified as supply of services, the questions regarding the classification as supply of goods and related tax rates are not applicable.

Ruling:
a) The activity of printing (Question Papers, OMR Sheets, Answer Sheets, Marks Sheets, Certificates) is classified as supply of services.

b) The benefit of serial no. 66 of Notification No. 12/2017-CTR dated 28.06.2017 is allowable for services related to the conduct of examinations by educational institutions.

c) The classification as exempted goods under serial no. 119 is not applicable.

d) The classification under schedule I at serial no. 201 is not applicable.

e) The printing of stationery (Question Papers, Admit Cards, Answer Booklets, Certificates, etc.) on behalf of educational boards and universities constitutes a supply of services and qualifies for exemption under serial no. 66 of Notification No. 12/2017-CT (Rate).

This ruling is valid within the jurisdiction of the Authority for Advance Ruling, Uttar Pradesh, and subject to the provisions under Section 103(2) of the CGST Act, 2017, until declared void under Section 104(1) of the Act.

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