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Case Law Details

Case Name : In re NCS Pearson INC (GST AAR Karnataka)
Appeal Number : Advance Ruling No. KAR ADRG 37/2020
Date of Judgement/Order : 22/05/2020
Related Assessment Year :
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In re NCS Pearson INC (GST AAR Karnataka)

he applicant is an intermediary located in non taxable territory and provides services of online exams/tests via electronic software to the non taxable online recipients in India which he has classified into three categories. For activities mentioned under Type l, the applicant is clear regarding the taxability and has approached the Authority only for Type 2 and Type 3 activities performed by them. In the following paras, we will discuss Type 2 and Type 3 activities as mentioned by the applicant.

Type 1 Test:

Tests that are self-administered by the candidates (‘test-takers’) and are wholly digital in nature. The test contains only multiple choice questions. The test-taker uses an Internet browser for the entire process ranging from creating a personal profile, selecting the desired test, remitting payment, taking the test, scoring and viewing results. The tests are not required to be taken from the test centers and can be taken from any location as desired by the candidate. The scores are provided by the electronic software based on a computer-based algorithm in its entirety and the test-taker gets the result in electronic format immediately on completion of the test. In view of this, the entire test experience is electronic without any human intervention.

Type 2 Test:

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