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Advance rulings (AAR) West Bengal

GST on Printing Question Papers for Educational Institutions

Printing question papers for educational institutions is an exempt service, meaning no GST is charged and no input tax credit is allowed.

Ruling
18/WBAAR/2018-19 dated 28.09.2018
Authority
Authority for Advance Ruling

This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.

The short version

  1. Printing question papers is classified as a service, not a supply of goods.
  2. Services provided to educational institutions for exams are exempt from GST.
  3. Suppliers cannot claim input tax credit on materials used for exempt services.

In short

The company asked the West Bengal Authority for Advance Ruling (AAR) whether printing question papers for universities and boards is a supply of goods or services, and if they could claim input tax credit on the paper and ink used.

What has changed

How it worked before

Printers were often unsure if their work should be taxed as a sale of printed goods or as a service, leading to inconsistent practices regarding GST collection and credit claims.

What has changed

The authority ruled that this activity is a service under SAC 9992 and is exempt from GST. Because the final service is exempt, the printer cannot claim input tax credit on the inputs like paper and ink used to produce the papers.

Who this affects

Printing businesses that provide question papers or similar materials to schools, universities, and examination boards.

An example

A local printing press in another state is hired by a university to print exam papers. They wonder if they should charge GST or if they can claim credit for the paper they bought. Based on this ruling, they would likely classify their work as an exempt service and realize they cannot claim credit for the GST paid on their paper purchases.

What you should do

This ruling only applies to the specific business that asked the question. If you are in the same industry, you should consult with your tax advisor to see if your specific contract matches these facts, as a ruling is not a law that automatically applies to everyone.

If you do nothing

If you assume this ruling applies to you and stop claiming input tax credit without confirming your specific situation, you may lose out on legitimate tax benefits. Conversely, if you incorrectly charge GST when you should be exempt, you may face disputes with your clients or tax authorities. Always verify your specific tax position with a professional.

The terms explained

Input tax credit
The GST a business pays on its own purchases, which it can usually subtract from the GST it collects from customers.
SAC code
A system of codes used to classify services for tax purposes, similar to how HSN codes classify goods.
Exempt service
A service on which no GST is charged, meaning the provider also cannot claim credit for taxes paid on their business expenses.

The ruling in detail

Authority for Advance Ruling

Ashok Kumar Basu, carrying on business under the trade name Manali Enterprise

18/WBAAR/2018-19 dated 28.09.2018 · West Bengal

Questions before the authority

  • Whether GST is to be charged on the supply of printed question papers and, if so, at what rate and under what HSN or SAC code?
  • Whether credit of the GST paid on the inputs used for provisioning the supply can be availed?

Facts

The applicant is engaged in printing question papers for various educational boards, councils, and universities. The institutions provide the content, while the applicant provides the paper, ink, and other inputs to print the material in a specific format. The applicant sought a ruling on the classification of this activity and the eligibility to claim input tax credit.

Ruling

QuestionWhat the authority ruled
ClassificationSAC 9992
Classified as a service related to education
TaxabilityExempt
Exempt under Notification 12/2017-CT(Rate)
Input Tax CreditNot eligible
Denied because the output supply is exempt

The authority held that the activity constitutes a supply of services rather than goods, classifiable under SAC 9992. It further ruled that the service is exempt from GST as it relates to the conduct of examinations. Consequently, the applicant is not eligible to claim input tax credit on inputs used for this supply.

Reasoning

The authority determined that the applicant does not own the content and cannot transfer title, thus the activity is a service of printing. It relied on Serial No. 66(b)(iv) of Notification 12/2017-CT(Rate), which **wholly exempts services provided to an educational institution** relating to the conduct of examinations. Because the output supply is exempt, Section 17(2) of the GST Act prohibits the applicant from claiming input tax credit on the inputs used for that supply.

Provisions relied on

  • Section 2(52) of the GST Act
  • Section 2(102) of the GST Act
  • Section 7 of the GST Act
  • Section 17(2) of the GST Act
  • Section 97(2)(a),(d)&(e) of the GST Act
  • Notification No. 12/2017-CT(Rate) dated 28/06/2017
  • Notification No. 14/2018-CT(Rate) dated 26/07/2018

For the practitioner

This ruling confirms that printing question papers for educational institutions is an **exempt service under SAC 9992** rather than a supply of goods. Practitioners should note that this exemption precludes the supplier from claiming input tax credit on related purchases. It provides clarity for printers serving government and private educational boards regarding their tax liability and credit eligibility.

Source

This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.

Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/wb_18_2018-19_dt_28.09.18_akb.pdf

Legibility of the scan, as read: high.

Prepared 21-10-2026.

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Is this ruling binding on my business?

No. An advance ruling is only binding on the business that requested it and their specific tax officer.

Can I claim input tax credit if my service is exempt?

No. Under GST law, if your output service is exempt, you are generally prohibited from claiming input tax credit on the materials used to provide that service.

What if my tax officer disagrees with this ruling?

Since this ruling is not a law for your business, your tax officer is not required to follow it. You must follow the rules as they apply to your specific circumstances.