Printing question papers is supply of service and printing answer booklets is supply of goods: Karnataka AAR

Printing question papers is supply of service and printing answer booklets is supply of goods: Karnataka AAR

The two-member bench of M.P.Ravi Prasad and T.Kiran Reddy has observed that the GST exemption is available on the question papers. However, GST is payable on the answer booklets.

The Karnataka Authority of Advance Ruling (AAR) in its recent ruling held that the printing of question papers constitutes a supply of service and the printing of answer booklets constitutes a supply of goods.

The applicant P.K.S Centre for Learning stated that they are proposing to submit a bid in response to the tender floated by the Karnataka Secondary Education Examination Board for the printing of question papers and other examination materials.

The applicant submitted that the Karnataka Secondary Education Examination Board is a statutory body established under the Karnataka Secondary Education Examination Board Act, 1966, for the purpose of holding and conducting public examinations.

The applicant stated that the conduct of examinations is an essential and inseparable part of education and a standardized measure of progress through the system.

The applicant stated that the proposed activity of contract printing stationery items for the Karnataka Secondary Education Examinations Board and using them for examinations would constitute the supply of service to an "educational institution" as defined in Notification No.12/17-CT(R).

The applicant has sought an advance ruling on the issue of whether the activity of printing stationery items such as question papers, admit cards, answer booklets, SSLC Pass Certificates, etc. on a contract basis for the Karnataka Secondary Education Examinations Board, and utilized for the conduct of examinations, would constitute a supply of service to an "educational institution".

Yet another issue raised was whether the service provided to educational institutions, specifically the Karnataka Secondary Education Examinations Board, by way of printing of stationery pertaining to the conduct of examinations, would be nil GST rate.

The AAR has observed that the Karnataka Secondary Education Examination Board is an educational institution for the limited purpose of providing services by way of the conduct of examinations to students.

The AAR observed that the activity of printing stationery items such as question papers, admit cards, SSLC Pass Certificates, the overprinting of variable data and lamination, fail marks cards, circulars, and ID Cards on a contract basis for the Karnataka Secondary Education Examinations Board and utilized for the conduct of examinations, would constitute a supply of service to an "educational institution".

The AAR held that the activity of printing stationery items such as answer booklets, other formats used for and during examinations, and envelopes for packing answer booklets on a contract basis for the Karnataka Secondary Education Examinations Board and utilized for the conduct of examinations, would constitute a supply of goods to an "educational institution."

"The services provided by the applicant to educational institutions (KSEEB) by way of printing of stationery pertaining to the conduct of examination covered under para i(a) supra is exempted as per entry No.66 (Heading 9992) of Notification No.12/ 2017-Central Tax (Rate), dated 28th June, 2017 as amended vide Notification No.02/ 2018-Central Tax (Rate) dated 25th January, 2018," the AAR added.