GST On Printing Services Provided To Educational Institutions
M/s Mehra Computer
Systems Limited, a Chennai-based company specializing in high-end security
printing, sought an advance ruling on the applicability of GST exemption on
services related to the printing of pre- and post-examination materials (like
question papers, OMR sheets, answer booklets, mark sheets, certificates, etc.)
and the processing of exam results, when provided to educational institutions.
The applicant argued that their services are integrally related to the conduct
of examinations and thus qualify for exemption under Sl. No. 66 of
Notification No. 12/2017-CGST (Rate). The Tamil Nadu Authority for Advance
Ruling agreed with the applicant, holding that such services qualify as composite
supplies with printing as the principal supply, and are exempt from GST
when provided to educational institutions as defined in the said notification.
· Advance
Ruling Number: 04/ARA/2025
· Date
of Ruling: 12 February 2025
· Ruling
Authority: Authority for Advance Ruling, Tamil Nadu
· Name
of Applicant: M/s Mehra Computer Systems Limited
Summary of
Advance Ruling:
The Authority held that
all three categories of services—(i) printing of pre-examination materials
(question papers, hall tickets, answer booklets, OMR sheets), (ii) printing of
post-examination materials (mark sheets, certificates, rank cards), and (iii)
scanning and processing of results—are exempt from GST under Sl. No. 66 of
Notification No. 12/2017-CT(Rate), when supplied to educational
institutions as defined under the said notification. These services were
found to be composite supplies with printing being the principal component,
and are integrally linked to the conduct of examinations.
Questions
Raised Before the Authority:
1. Whether
the printing of pre-examination items like hall tickets, question papers, OMR
sheets, and answer booklets for educational boards is exempt under Sl. No.
66 of Notification No. 12/2017-CT(Rate) as amended?
2. Whether
the printing of post-examination materials like mark sheets, degree
certificates, rank cards, etc., after processing the OMR sheets, is exempt
under the same notification?
3. Whether
services like scanning and processing of exam results provided to
educational boards are exempt under this notification?
Relevant
Legal Provisions:
- Sl. No. 66(b)(iv)
of Notification No. 12/2017-CT(Rate) dated 28.06.2017
- Amended by Notification No.
02/2018-CT(Rate) dated 25.01.2018
- Circular No. 151/07/2021-GST,
CBIC dated 17.06.2021
- Section 2(90)
– Principal Supply
- Heading 9989
– Printing services
Applicant’s
Submissions:
- The applicant offers end-to-end
printing services to educational institutions, using customer-provided
designs and data.
- The materials are tailored and cannot
be reused or resold.
- The services are part of the examination
process, including printing and result processing.
- Cited various similar rulings
supporting GST exemption:
- Hi-tech Print Systems Ltd
(Telangana)
- Orient Press Ltd (Maharashtra)
- Edutest Solutions Pvt. Ltd (Gujarat)
- Sarswathy Press Ltd (West Bengal)
- Vanijya Therige Karyalaya
(Karnataka)
Discussion
and Findings by Authority:
- The services are composite in
nature, involving both supply of goods (paper) and services
(printing), but the principal supply is printing.
- Circular No. 151/07/2021
clarified that services related to conduct of examinations—such as
printing of question papers, hall tickets, result publication—are exempt
when provided to educational institutions.
- The ruling also emphasized that
exemption is only applicable to services, not to goods.
- The applicant’s services are directed
solely to educational institutions recognized under law, satisfying
the condition for exemption.
Answers to
the Questions:
1. Yes
– Services of printing hall tickets, question papers, OMR sheets, and answer
booklets for educational institutions are exempt from GST under Sl. No.
66 of Notification No. 12/2017-CT(Rate).
2. Yes
– Printing of post-examination items like mark sheets, degree certificates, and
processing of data is exempt when provided to educational institutions.
3. Yes
– Services of scanning and processing of results for educational
institutions are exempt under the same notification.
Conclusion:
The Authority confirmed
that all services rendered by M/s Mehra Computer Systems Ltd to educational
institutions in relation to conduct of examinations—including printing
and scanning—qualify as exempt services under Sl. No. 66 of Notification
No. 12/2017-CT(Rate). The core element of the supply is printing (a
service), and the exemption applies when supplied exclusively to educational
institutions recognized by law.
Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.
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