Order Date – 22 September 2023

Facts –

• The Applicant, M/s. V S Hi-Tech Security Forms Private Limited, is engaged in the business of printing of Security printing products like, barcoded OMR answer booklets, OMR sheets, Certificates, Marks Memos.
• The applicant conteded that they provide printing services to various educational institutions based on their requirements using the paper and ink of the applicant. That the products are designed and printed as per the requirements of particular customer and that such products cannot be delivered to any other person as printing in the applicant case is combined with security features.

Issue –

• Whether the exemptions in terms of serial Number 66 of Notification No.12/2017-CGST (Rate), dated 28-06-2017are available for printing of examination items and scanning and processing of results of examinations?

Order –

• The AAR observed that thr content to be printed is based on the specifications given by the educational institutes and the applicant has no role in deciding the same. Therefore supply of printing [of the content supplied by the recipient of supply] is the principal supply and the same is clarified by Circular No. 11/11/2017-GST dated 20.10.2017.
• Supply of test papers/question papers would constitute supply of service falling under heading 9989 of the scheme of classification of services as the usage rights of the manuscript material of Question Papers/test papers (intangible inputs) are owned by the Educational Institutes and the physical inputs used for printing the same belong to the applicant.
• It was clarified that GST is 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 educational institutions under S. No. 66 (b) (iv) of Notification No. 12/2017-CT(R). Therefore the suppliers of these services can avail the benefit of exemption from payment of GST on these services.
• Hence printing of  Pre- examination items, Post-examination items Scanning and processing of results of examinations are exempted from GST as per S. No. 66 (b) (iv) of Notification No. 12/2017-CT(R).