TaxTMI 
TaxTMI 
2026 (4) TMI 352
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....stion paper shall be provided by the Universities, and the applicant shall not deviate the specifications and the standards given by the Universities. 3. The Applicant has sought advance ruling in respect of the following question: "Whether the printing of exam papers provided to universities is exempt from tax in terms of sl.no.66 (b) (IV) of the Notification No. 12/2017-Central (Tax) Rate dated 28.06.2017, as amended." 4. Admissibility of The Application: The Applicant, under Column 13 of Form ARA-01, has selected two categories of issues, namely: (i) Applicability of a notification issued under the provisions of this Act, and (ii) Determination of the liability to pay tax on any goods or services or both. On examination of the nature of the questions raised and the issues involved, it is found that the applicant has correctly selected the said categories of issues. Accordingly, the present application is held to be admissible in terms of Section 97(2)(b) and Section 97(2)(e) of the CGST Act, 2017. 5. Brief Facts of The Case:- The Applicant is engaged in supplying of printing services of exam papers to various universities. They prints and s....
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....xmann.com 240 / (26) G.S.T.L. 369 (AAR-Mah.) (GST/ARA/89/2018-19/B-23, dated 27.02.2019); • Ashok Kumar Basu (Manali Enterprises), In re [18/WBAAR/18-19, dated 28.09.2018] {2018 (18) G.S.T.L. 49 (AAR-GST)}; • Hitech Print Systems Ltd., In re [2021] 131 taxmann.com 29/88 GST 527/ (55) G.S.T.L. 69 (AAR-AP) {24/AP/GST/2020, dated 15.12.2020}; • Management & Computers Consultants, In re [2021] 133 taxmann.com 100/[2022] 89 GST 752/(60) G.S.T.L. 505 (AAR-WB) {08/WBAAR/2021-22, dated 13.09.2021}. 7. PERSONAL HEARING PROCEEDINGS HELD ON 18.12.2025:- CA Rajesh Kumar T.R. and CA Kruthika K.N., the duly authorised representatives of the applicant, appeared for the personal hearing held on 18.12.2025 before this Authority and reiterated the facts as narrated in the application. They also placed reliance on the decision of the Hon'ble Karnataka High Court in the case of Rajiv Gandhi University of Health Sciences [(2024) 22 Centax 526 (Kar.)], wherein it was held that a university is also an educational institution as per the definition provided under the service tax exemption notification. The said decision was affirmed by the Hon'ble Supreme Court,....
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....y and staff; (ii) catering, including any mid-day meals scheme sponsored by the Central Government, State Government or Union territory; (iii) security or cleaning or housekeeping services performed in such educational institution; (iv) services relating to admission to, or conduct of examination by, such institution; (v) Supply of online educational journals or periodicals. Provided that nothing contained in sub-items (i), (ii) and (iii) of item (b) shall apply to an educational institution other than an institution providing services by way of pre-school education and education up to higher secondary school or equivalent: Provided further that nothing contained in sub item (v) of item (b) shall apply to an institution providing services by way of,- (i) Pre-school education and education up to higher secondary school or equivalent; or (ii) Education as a part of an approved vocational education course. NIL NIL Clause 2(y) of the Definitions under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as amended, defines "Educational Institution" as under: "Educational institution" means an institu....
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....raining given by private coaching institutes would not be covered as such training does not lead to grant of a recognized qualification. 12.5 Universities on which services provided by the applicant are established under Central or State enactments and are statutorily empowered to prescribe curricula, conduct examinations, and award degrees or diplomas. The degrees and qualifications conferred by universities are recognised under the relevant laws governing higher education, including the University Grants Commission Act, 1956, and the respective University Acts. The education imparted by universities is structured, curriculum-based, and culminates in the award of qualifications recognised by law. Therefore, universities squarely fall within the ambit of sub-paragraph (ii) of paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate), and accordingly qualify as "educational institutions" for the purposes of the said notification. 12.6 Having held that universities qualify as "educational institutions" in terms of paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, the next issue to be examined is whether the services provided by the applicant....