2026-VIL-38-AAR
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SGST Advance Ruling Authority

GST – Rajasthan AAR - Maintainability of Advance Ruling Application by Service Recipient - Section 95(a) and Section 97(2) of the CGST Act, 2017 - The applicant, a State Educational Board, sought Advance ruling regarding applicability of GST on various services it received from third-party suppliers - Whether a recipient of services is legally entitled to seek an Advance Ruling – Taxability of services provided to the Board as services relating to the conduct of examination by an educational institution - HELD - The definition of "applicant" under Section 95(a) is intentionally broad, encompassing any person registered or desirous of obtaining registration under the Act. The scope of an applicant is not restricted to suppliers, a person liable to pay tax under reverse charge or any recipient of service may seek an Advance Ruling on matters specified under Section 97(2) of the Act. Accordingly, the application is maintainable - The applicant-Board engaged suppliers for various services including the printing of answer sheets, question papers, and certificates, online examination form filling, annual maintenance of computers used exclusively for exams, result processing through marks allotment, and provision of computer operators. By virtue of Explanation (iv) to paragraph 3 of Notification No. 12/2017-CT(Rate) (as inserted by Notification No. 14/2018), Central and State Educational Boards are treated as "educational institutions" for the limited purpose of providing services by way of conduct of examination to students. Since the services enumerated by the applicant—including printing, IT support for forms and results, and operational assistance—are integral, directly connected, and exclusively utilized for the examination process, they fall squarely within the exemption provided under Entry 66(b)(iv) of the said notification. The exemption is not limited to the Board's output services but extends to specific input services received by the Board that are necessary for conducting examinations - All the services mentioned in the application are found to be in relation to the conduct of examination and hence are covered under the exemption available vide Entry No. 66(b)(iv) of Notification No. 12/2017-CT (Rate) – Ordered accordingly
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