Exam Support Services Attract 18% GST as Composite Supply
Haryana AAR ruled that providing bundled exam support services for IELTS is a composite supply subject to 18% GST under SAC 999299.
- Ruling
- HAR/HAAR/R/2017-18/11, dated 01.06.2018
- Dated
- 01 Jun 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
- BC Examinations asked if exam support services count as a composite supply
- They sought clarity on the GST rate for back-end exam facilitation
- Haryana AAR ruled that exam administration support is a composite supply
- The principal supply is educational support taxed at 18% GST
- The authority rejected deciding place of supply due to legal limits
In short
BC Examinations and English Services India Pvt. Ltd. approached the Haryana Authority for Advance Ruling under order HAR/HAAR/R/2017-18/11 to clarify how Goods and Services Tax (GST) applies to their end-to-end support for foreign English tests like IELTS. They asked whether activities like venue sourcing, printing test materials, and managing invigilators form a composite supply, what GST rate applies, and what the place of supply is.
What has changed
How it worked before
Businesses offering combined administrative, logistical, and staffing support for tests were unclear whether to split their invoices into separate services or treat them as a single packaged service under GST.
What has changed
The authority decided that providing full exam management is a single composite supply because all individual tasks naturally bundle together to conduct an exam. The main service is educational support under SAC 999299, making the entire service package taxable at 18% GST (9% CGST + 9% HGST).
Who this affects
Testing agencies, event managers, and service providers offering end-to-end exam facilitation, student administration, or venue coordination for foreign or domestic institutions.
An example
Alpha Assessment Services signs an agreement with an overseas university to run entrance tests across India. Alpha handles venue bookings, distributes question papers, hires invigilators, and collects answer sheets for a single fee. Based on this ruling, Alpha would treat all these activities as a composite supply of educational support services and charge 18% GST on the full contract value.
What you should do
Review your operational contracts to see if your services are naturally bundled around one main goal. Remember that an advance ruling applies legally only to the company that requested it, so you should consult a tax professional rather than treating this decision as automatic law.
If you do nothing
If you assume this ruling covers your business and break your services into lower-taxed components, a tax officer may assess your operations during an audit. If they find your services were naturally bundled, they can reclassify them as educational support under SAC 999299. This will lead to demands for short-paid GST at 18%, along with interest and late penalties.
The terms explained
- composite supply
- A package of two or more goods or services naturally sold together in business, where one main service leads the bundle.
- principal supply
- The primary or most important service in a combined bundle that determines how the whole package is taxed.
- mixed supply
- A combination of separate goods or services sold together for a single price, which are not naturally dependent on each other.
- SAC 999299
- The official service code used under GST to categorize education support services.
The ruling in detail
Authority for Advance Ruling
M/s BC Examinations and English Services India Pvt. Ltd.
HAR/HAAR/R/2017-18/11, dated 01.06.2018 · Haryana
Questions before the authority
- 1. Whether all the activities involved in the exam support services constitute a mixed supply or a composite supply?
- 2. What will be rate of GST applicable on these exam support services?
- 3. What is the place of supply of these exam support services rendered by the Applicant t BCKU?
Facts
The Applicant, an Indian subsidiary of British Council (UK), proposed to enter into an agreement with its overseas parent to provide Exam Support Services and Student Facilitation Services for conducting IELTS examinations in India. The services included sourcing venues, managing candidate registrations, test materials, logistics, result printing, invigilator management, and quality control. The Applicant approached the Authority to clarify the classification, nature of supply, applicable GST rate, and place of supply for these bundled back-end support activities.
Ruling
| Question | What the authority ruled |
|---|---|
| Nature of supply (mixed vs composite) | Composite supply Activities proposed under Schedule 1 Part-A and B are naturally bundled to conduct IELTS exams |
| Rate of GST applicable on exam support services | 18% (9% CGST and 9% HGST) Covered under Service Code 999299 Group 99929 and Heading 9992 as education support service vide sr. no. 30 of notification no. 11/2017-Central Tax (Rate) |
The Authority held that the activities involved in providing exam support services constitute a **composite supply**, as they are naturally bundled and rendered in conjunction with each other to conduct IELTS exams. The principal supply is the service of conducting examinations, classifiable under SAC 999299 (Education Support Services), which is taxable at **18% GST (9% CGST + 9% HGST)**. The question on place of supply was not admitted as it falls outside the jurisdiction of the Advance Ruling Authority under Section 97(2) of the CGST Act.
Reasoning
The decision turned on Sections 2(30), 2(74), and 2(90) of the CGST/HGST Act, 2017, defining composite supply, mixed supply, and principal supply. The Authority noted that the various administrative, logistical, venue management, invigilation, and student facilitation activities are performed exclusively to facilitate IELTS examinations and cannot exist independently. Therefore, these ancillary support activities form a naturally bundled composite supply with the principal supply being the service of conducting examinations. As per Heading 9992 (SAC 999299) of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017, education support services attract GST at the rate of 18%.
Provisions relied on
- Section 2(30) of the CGST Act, 2017
- Section 2(74) of the CGST Act, 2017
- Section 2(90) of the CGST Act, 2017
- Section 97(2) of the CGST Act, 2017
- Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017 (Sr. No. 30)
- Notification No. 46/ST-2 dated 30.06.2017
For the practitioner
This ruling establishes that comprehensive administrative, logistical, and operational support services provided for conducting standardized educational tests constitute a **composite supply of educational support services** under SAC 999299 taxable at 18%. Tax practitioners should note that back-end support rendered for global examinations is treated as naturally bundled with exam delivery, while place of supply determinations remain outside the purview of the Authority for Advance Ruling.
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/haryana-ar_11_2017-18_dt.01.06.18_bceesipl.pdf
Legibility of the scan, as read: high.
Prepared 18-10-2026.
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