No GST on Printing Post-Examination Items like Mark Sheets, Degree Certificates, Grade and Rank Sheets, Rank Cards & Certificates for Educational Institutions: AAR [Read Order]

The Tamil Nadu Authority for Advance Ruling (AAR) recently held that services such as printing post-examination items like mark sheets, degree certificates, grade sheets, rank cards and other related documents, when rendered to educational institutions, shall be exempt from the levy of Goods and Services Tax (GST).

M/s Mehra Computer Systems Limited (Mehra Computer Systems), a Chennai-based enterprise engaged in high-security printing solutions for educational institutions filed an application for Advance Ruling before the Authority seeking clarity on the taxability of multiple services rendered to educational institutions.

Among the queries raised, the applicant specifically sought a ruling on whether the services of printing post-examination items such as mark sheets, degree certificates, rank and grade sheets, certificates and rank cards after scanning and processing data would fall under the exemption provided at Serial No. 66 of Notification No. 12/2017-CT (Rate) dated 28.06.2017 and as amended by Notification No. 02/2018-CT (Rate) dated 25.01.2018.

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GST Practitioner Kalyanasundaram Baskaran appeared as the authorised representative for Mehra Computer Systems during the personal hearing and reiterated the submissions made in the application, explaining the end-to-end nature of services provided by the applicant. The applicant clarified that the post-examination documents are generated using content and data provided by the universities, following completion of evaluation and scanning of OMR sheets.

The Bench comprising Balakrishna S (CGST Member) and B. Suseel Kumar (SGST Member) took note of the fact that the applicant uses their own materials including paper, ink and technology to deliver final printed post-examination deliverables in a secure manner.

The Bench referred to Circular No. 151/07/2021-GST dated 17.06.2021 which clarified that input services relating to conducting examinations, including publication of results, printing of mark sheets and certificates are exempt when supplied to educational institutions.

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The AAR further observed that the nature of the supply constituted a composite supply, wherein printing constituted the principal element. Given that the items in question were directly related to the outcome of examinations conducted by educational institutions, the Authority concluded that such services fell squarely within the scope of the exemption provided under Serial No. 66 of the said Notification.

Accordingly, the Authority ruled that such services, when supplied to educational institutions in connection with the conduct and outcome of examinations, shall be treated as an exempt supply under the GST regime.

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