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2021 (8) TMI 574 - AAR - GSTExempt supply of service or not - printing of Pre examination items like question papers, OMR sheets (Optical Mark Reading), Answer booklets for conducting of an examination by the educational boards - printing of Post examination items like marks card, grade card, certificates to educational boards (up to higher secondary) after scanning of OMR Sheets and processing of data in relation to conduct of an examination - scanning and processing of results of examinations - Serial Number 66 of Notification No. 12/2017-CGST Rate dated 28-06-2017 as amended. HELD THAT - In the instant case, the educational institutions as referred to by the applicant for whom the supplies of the services of printing of examination related material are made/ intended to be made are Mumbai university examination Committee, Bihar University Examination Committee, JNTU, Kakinada. All of the three institutions invariably fall under the category of educational institution as they fulfil the criterion of 'institution providing services by way of,- (ii) education as a part of a curriculum for obtaining a qualification recognised by any law for the time being in force;'. Further, with reference to the services provided by the applicant, they are nothing but 'services relating to admission to, or conduct of examination by, such institution' falling under Si.No.66 of the said exemption notification of No. 12/2017-CGST Rate dated 28.06.2017 as amended. Thus, all supply of services are exempt supply.
Issues Involved:
1. Classification of printing pre-examination items as exempted supply of service. 2. Classification of printing post-examination items as exempted supply of service. 3. Classification of scanning and processing of examination results as exempted supply of service. Issue-wise Detailed Analysis: 1. Classification of Printing Pre-examination Items: The applicant, M/s. Hitech Print Systems Limited, sought clarification on whether the printing of pre-examination items like question papers, OMR sheets, and answer booklets for educational boards is considered an exempted supply of service under Serial Number 66 of Notification No. 12/2017-CGST [Rate] dated 28-06-2017 as amended. The applicant argued that these services are essential for the conduct of examinations and fall under the exemption provided to educational institutions. The ruling confirmed that these services are indeed exempted, as they are directly related to the conduct of examinations by educational institutions, which are recognized under the notification. 2. Classification of Printing Post-examination Items: The applicant also sought clarification on whether the printing of post-examination items such as marks cards, grade cards, and certificates, after scanning OMR sheets and processing data, is considered an exempted supply of service. The applicant contended that these services are the final step in the examination process and thus should be exempt. The ruling agreed, stating that these services are part of the examination process and fall under the same exemption as pre-examination services. 3. Classification of Scanning and Processing of Examination Results: The applicant further sought clarification on whether the scanning and processing of examination results are considered exempted services. The applicant argued that these services are integral to the examination process and should be exempt under the same notification. The ruling affirmed this position, stating that these services are related to the conduct of examinations and are thus exempt from GST. Discussion and Findings: The ruling examined the submissions and supporting documents provided by the applicant, including purchase orders and tender documents from various educational institutions. The ruling referenced the CBIC Circular No. 11/11/2017-GST, which clarifies that services involving the printing of content provided by the recipient are considered supply of service. The educational institutions in question, such as Mumbai University and JNTU Kakinada, were recognized as educational institutions under the notification. The services provided by the applicant were deemed to be related to the conduct of examinations, thus qualifying for exemption under Serial Number 66 of Notification No. 12/2017-CGST [Rate] dated 28-06-2017 as amended. Ruling: 1. Printing of pre-examination items like question papers, OMR sheets, and answer booklets for conducting examinations by educational boards is treated as exempted supply of service. 2. Printing of post-examination items like marks cards, grade cards, and certificates to educational boards after scanning OMR sheets and processing data is treated as exempted supply of service. 3. Scanning and processing of examination results is treated as exempted supply of service. The ruling conclusively affirmed that the services provided by the applicant to educational institutions for the conduct of examinations are exempt from GST under the specified notification.
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