In re Mehra Computer Systems Limited (GST AAR Tamilnadu)
Tamil Nadu Authority for Advance Ruling (AAR) examined the applicability of the Goods and Services Tax (GST) on the printing services provided by M/s. Mehra Computer Systems Limited. The applicant, engaged in printing question papers, OMR sheets, hall tickets, and mark sheets for universities and educational institutions, sought clarification on whether these services are exempt under GST. The AAR considered the relevant provisions, including Notification No. 12/2017-CT (Rate) and Circular No. 151/07/2021-GST, to determine the classification and taxability of these services.
The applicant argued that its services should be classified under printing services (HSN 9989) and qualify as exempt under Serial No. 66(b)(iv) of Notification No. 12/2017-CT (Rate). This provision exempts services provided to educational institutions in relation to conducting examinations. The applicant further emphasized the confidentiality and security measures undertaken in printing these materials, ensuring the integrity of examination processes. These arguments were supported by Circular No. 151/07/2021-GST, which clarified that pre- and post-examination services provided to educational boards are exempt from GST.
The AAR ruled in favor of the applicant, holding that the printing of pre-examination materials such as question papers, hall tickets, and OMR sheets qualifies as an exempt supply under the said notification. Similarly, post-examination services, including scanning and processing results, printing mark sheets, and issuing certificates, were also considered exempt when provided to educational institutions. The ruling was in line with previous judgments, such as the decision in National and State Boards (Circular No. 151/07/2021-GST), which affirmed that services related to conducting examinations are not taxable.
