In re Codeword Process And Printers (GST AAR Karnataka)
The applicant filed an application for advance ruling under the CGST and KGST Acts seeking clarity on whether printing of examination question papers for universities qualifies for GST exemption under Entry No. 66(b)(iv) of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.
The applicant is engaged in printing exam papers strictly as per the specifications, format, design, and standards prescribed by universities. The applicant does not exercise any discretion in the printing process and supplies the printed question papers as approved by the universities.
The applicant contended that the services provided fall within the scope of Entry No. 66(b)(iv), which exempts services provided to educational institutions by way of services relating to admission or conduct of examinations. It was argued that the expression “relating to” has a wide scope and includes ancillary services such as printing of question papers. The applicant also relied on the definition of “educational institution” under the notification, stating that universities qualify as such institutions since they provide education as part of a curriculum leading to a qualification recognized by law.
The Authority examined the relevant provisions, including Entry No. 66 and the definition of “educational institution” under paragraph 2(y) of the notification. It observed that universities do not fall under pre-school or vocational education categories but qualify under the category of institutions providing education as part of a curriculum leading to recognized qualifications. Universities are established under statutory enactments, empowered to prescribe curricula, conduct examinations, and award degrees or diplomas recognized by law. Therefore, they are covered within the definition of “educational institution.”
