The Telangana Authority for Advance Ruling has held that the supply of printing services provided to educational institutions for question papers, OMR sheets, answer sheets, marks card exempted from Goods and Service Tax .
The applicant Y S Hitech Secure Print Private Limited, is engaged in the business of Security printing products like, question papers for conducting examinations, barcode, OMR answer booklets, OMR sheets, Certificates, Marks Memo, MICR cheque books and other books and certificates.
The applicant has sought an advance ruling in respect exemption from GST supply of printing services like question papers, OMR sheets, Answer sheets, marks card etc to an educational institution
M.Ramchandra Murthy on behalf of the applicant submitted that Sr. No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 (tax free services) refers to Heading 9992 Educational services, which includes pre-primary education services, primary education services, secondary education services, higher education services, specialized education services and also other education and training services and education support services.
Further, services are covered at Sr. No. 66(b)(iv), which covers “Services provided to an educational institution, by way of, services relating to admission to, or conduct of examination by, such institution, upto higher secondary‟.
During the proceedings, the authority discussed that the supply made by the applicant could not be classified as selling of question papers to the educational institutes as the content to be printed on them is given by the latter to the applicant.
The supply of Printed Question Papers could not be used where readymade printed material is bought by the recipient who does not own the content in the material to be bought, but it is a composite supply providing printing services on the papers owned by him.
Thus, this composite supply involves both supply of printing services and supply of the paper owned by him on which the printing is done as per the content given by the educational institutes.
As per the Circular No. 11/11/2017-GST dated 20.10.2017 it was mentioned that,
“In the case of printing of books, pamphlets, brochures, annual reports, and the like, where only content is supplied by the publisher or the person who owns the usage rights to the intangible inputs while the physical inputs including paper used for printing belong to the printer, supply of printing [of the content supplied by the recipient of supply] is the principal supply and therefore such supplies would constitute supply of service falling under heading 9989 of the scheme of classification of services.”
Further the CBIC has issued a Circular No. 151/07/2021- GST dated 17.06.2021 which clarified that
“ GST is also exempt on input services relating to admission to, or conduct of examination, such as online testing service, result publication, printing of notification for examination, admit card and questions papers etc, when provided to such Boards [under S. No. 66 (b) (iv) of notif No. 12/2017CT(R)].”
The two member bench of Authority of Advance Ruling, S.V. Kasi Visweswara Rao, Additional Commissioner (State Taxes) Sahil Inamdar I.R.S., Additional Commissioner (Central Taxes) observed that Supply of Printing of test papers/question papers, OMR sheets, Certificates, Marks Memo, MICR cheque books etc. using his own paper and ink to educational institutions is a composite supply, of which Printing services is the principal supply which makes the supply exempt from payment of GST.
Subscribe Taxscan Premium to view the JudgmentSupport our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
