The Andhra Pradesh Authority for Advance Ruling has recently, in an application filed before it, ruled that the scanning and processing of exam results are exempted from GST.
The aforesaid ruling was made by the Authority of Advance Ruling when an application was filed before it by M/s. Universal Print Systems, the applicant, who is engaged in the business of printing including high-end security printing products from the year 2011.
The Applicant being engaged in the supply of examination answer sheets which include optical character reading facilities, optical mark recognition features , printed only in the required numbers under strict confidentiality supervised by the educational authorities as per the approved design and pattern as is provided by such educational authority/board , the applicant was also involved in the printing of different types of certificates with security features so that the genuineness of these documents can be prevented from unauthorized misuse/duplication.
The aforesaid activity by the applicant also involved approved printing as per the design/pattern/data, as was provided by the customer under their supervision.
The primary question involved in the application filed by the applicant being as to whether the scanning and processing of results of examinations in relation to the aforesaid activities be treated as exempted supply of service, by virtue of the terms of Serial Number 66 of Notification NO. 12/2O17-CGST[Rate] dated 28-6-2017 as is amended, it was submitted by the applicant that before the onset of Goods and services Tax, the activity of the Applicant was treated as manufacture by classifying the products under chapter 49148 of the First schedule to the Central Excise Tariff Act, 1985. And simultaneously, that the clearance was treated as sale within the meaning of AP VAT Act, 2005.
With the applicant further adding to his submission that with the onset of Goods and services Tax in 2017, however, a different connotation has been accorded by treating the said activity as supply of service, instead of supply of goods in as much as the Applicant does not own the goods at any stage, in the view of the security features or the nature of the goods which cannot be sold to any other person due to fiduciary value, the services rendered in printing industry, particularly in cases where the design/data/pattern is provided by the customer, are recognized to be a service, the Andhra Pradesh Authority for Advance Ruling, consisting of the members Sri. D. Ramesh, the Commissioner of State Tax and Sri. RV Pradhamesh Bhanu, the Joint Commissioner of Central Tax Observed as follows:
“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 Sl No 66 of the said exemption notification of No. 12/2017-CGST [Rate], dated 28.06.2017 as amended.”
Thus, pronouncing its ruling in affirmation and thereby exempting scanning and processing of exam result from GST, the Andhra Pradesh Authority for Advance held :
“In view of the above foregoing, we concur with the opinion of the applicant .”
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