University examination printing services qualify as exempt services when they are integral to the conduct of examinations.
Universities qualify as educational institutions under Notification No. 12/2017-Central Tax (Rate) because they provide education through curricula leading to qualifications recognised by law, and they are exempt recipients for services covered by the notification. Printing of examination question papers supplied to universities is a service relating to the conduct of examinations, since it is integral and indispensable to that process and has a direct, proximate nexus with examination administration. On that basis, the printing service falls within Serial No. 66(b)(iv) and is exempt from GST.
Issues: (i) Whether universities are educational institutions within paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017; and (ii) whether printing of examination question papers supplied to universities falls under Serial No. 66(b)(iv) of the said notification and is exempt from GST.
Issue (i): Whether universities are educational institutions within paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
Analysis: The definition of educational institution covers institutions providing education as part of a curriculum for obtaining a qualification recognised by law. Universities are statutorily empowered to prescribe curricula, conduct examinations, and award degrees or diplomas. Their courses culminate in legally recognised qualifications, bringing them within the scope of paragraph 2(y).
Conclusion: Universities are educational institutions for the purposes of the exemption notification.
Issue (ii): Whether printing of examination question papers supplied to universities falls under Serial No. 66(b)(iv) of the said notification and is exempt from GST.
Analysis: Serial No. 66(b)(iv) exempts services provided to an educational institution by way of services relating to admission to, or conduct of examination by, such institution. The phrase "relating to" is of wide amplitude and covers services having a direct and proximate nexus with the conduct of examinations. Printing of question papers is an integral and indispensable part of the examination process and is therefore covered by the entry. The view is consistent with the departmental clarification relied upon and the settled position recognised in the cited authority concerning universities as educational institutions.
Conclusion: Printing of examination question papers supplied to universities is covered by Serial No. 66(b)(iv) and is exempt from GST.
Final Conclusion: The ruling accepts that universities qualify as educational institutions and that the applicant's printing service is an exempt service connected with the conduct of examinations.
Ratio Decidendi: Services that are integral to and have a direct and proximate nexus with the conduct of examinations by an educational institution fall within the exemption for services relating to conduct of examinations.
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