2026-VIL-193-AAR
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SGST Advance Ruling Authority

GST - Printing and supply of examination related items - Composite supply under Section 2(30) of the CGST Act, 2017 - Applicant printed and supplied pre-examination and post-examination items such as question papers, OMR sheets, answer booklets, hall tickets, mark sheets, grade sheets and degree certificates for educational boards and universities. The Applicant also scanned and processed OMR sheets and results. The content to be printed was provided by the educational institutions, while the paper belonged to the Applicant - Whether the printing and supply of examination related items is a supply of goods or a supply of services - HELD - The activity involves the supply of goods by way of paper on which the content is printed and the service of printing itself. Both happen concurrently and are bundled, which makes the activity a composite supply. The principal supply is the predominant element to which the other supply is ancillary. The institutions approached the Applicant for printing of content owned and provided by them and not for supply of paper. The predominant element is therefore the printing service. Where only the content is supplied by the recipient and the physical inputs including paper belong to the printer, printing of the content is the principal supply. Such supply constitutes a supply of service falling under heading 9989 - The printing and supply of examination related items is a supply of services. Ordered accordingly - Exemption for printing of pre-examination items - Serial No. 66 of Notification No. 12/2017-Central Tax (Rate) - Applicant printed and supplied hall tickets, question papers, OMR sheets and answer booklets, including transportation and delivery, for educational boards and universities. The Applicant was charging GST on these services - Whether the printing and supply of pre-examination items is exempt under Serial No. 66 - HELD - Under Serial No. 66(b)(iv), services provided to an educational institution by way of services relating to admission to, or conduct of examination by, such institution are exempt. Central and State Educational Boards are treated as educational institutions for the limited purpose of providing services by way of conduct of examination. Input services relating to the conduct of examination, such as printing of admit cards and question papers, are covered when provided to such institutions. The Applicant's printing is a service provided to educational institutions - The services of printing pre-examination items provided to educational institutions for conducting examination are exempt under Serial No. 66 of the Notification - Exemption for post-examination items and processing of results - Serial No. 66 of Notification No. 12/2017-Central Tax (Rate) - Applicant printed and supplied mark sheets, grade sheets, rank sheets and degree certificates, and scanned OMR sheets and processed results. The Applicant submitted that this activity forms the end of the examination process - Whether these post-examination services are exempt under Serial No. 66 - HELD - Processing and scanning of results and printing of mark sheets and certificates are essential for completing a qualification recognised by law. The post-examination activity is therefore in relation to conduct of examination. The reasons applicable to the pre-examination process apply equally to this activity - The services of printing post-examination items, including scanning of OMR sheets and processing of results provided to educational institutions, are exempt under Serial No. 66 of the Notification.
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