GST on printing question papers for educational institutions
- Ruling
- ADVANCE RULING NO. GUJ/GAAR/R/2018/16, dated 23.8.2018
- 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.
In short
The company asked the Gujarat Authority for Advance Ruling (AAR) whether printing question papers is a supply of goods or a service under the Goods and Services Tax (GST) law. This distinction is critical because it determines whether the activity is taxable or eligible for an exemption.
What has changed
How it worked before
Businesses were previously uncertain whether printing question papers should be treated as a sale of printed goods or a service provided to a client. Many printers were unsure if they should charge GST or claim an exemption based on the nature of their educational clients.
What has changed
The authority ruled that printing question papers is a supply of service, not a supply of goods. This means that if you provide this service to an educational institution for conducting exams, it is exempt from GST under Notification No. 12/2017-Central Tax (Rate).
Who this affects
This ruling is relevant for printing businesses, publishers, and service providers who handle confidential printing for schools, colleges, and examination boards.
What you should do
You should review your current contracts to see if your printing services qualify for this exemption. Please note that an Advance Ruling is only legally binding on the business that requested it and its specific tax officer, so you should consult with your tax advisor before changing your billing practices.
The ruling in detail
Authority for Advance Ruling
M/s. Edutest Solutions Private Limited
ADVANCE RULING NO. GUJ/GAAR/R/2018/16, dated 23.8.2018 · Gujarat
Questions before the authority
- Whether activity of printing of question papers on behalf of educational institutions can be classified as activity of supply of goods or supply of services.
- If it is supply of services, referring to Sr. No. 27 of Notification 11/2017-CTR dtd : 28.06.2017 as amended by Notification 31/2017-CTR dtd.: 13.10.2017, then benefit of Sr. No. 66 of Notification 12/2017-CTR dtd. : 28.06.2017 is allowable, as amended by Notification No. 2/2017-CTR of 25.01.2018; or
- If it is supply of goods, then question paper printing should be treated as exempted goods at Sr. No. 119 of exempted list liable at Nil rate of tax under Chapter heading / subheading of 4901 10 10 of “Printed books including Braille books”, or It should be covered by Schedule I at Sr. No. 201 liable to tax at 2.5% under “Brochures, leaflets and similar printed matter, whether or not in single sheets”.
Facts
The applicant is engaged in the confidential printing of educational test papers for various state and national education boards and institutes. The applicant receives manuscript material from these clients and performs the composition, typesetting, printing, packing, and delivery of the sealed question papers. The applicant sought a ruling on whether this activity constitutes a supply of goods or services and its taxability under GST.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of activity | Supply of service Classifiable under heading 9989 |
| Supply to educational institutions | Exempt Covered by Sr. No. 66 of Notification 12/2017-Central Tax (Rate) |
| Supply to other recipients | Taxable Covered by Sr. No. 27(i) of Notification 11/2017-Central Tax (Rate) |
The authority ruled that the activity is a **supply of service** classifiable under heading 9989. Services provided to educational institutions for the conduct of examinations are **exempt** under Sr. No. 66 of Notification No. 12/2017-Central Tax (Rate). For recipients other than educational institutions, the service is taxable under Sr. No. 27(i) of Notification No. 11/2017-Central Tax (Rate).
Reasoning
The authority determined that since the applicant uses its own paper but prints content owned by the client, the printing is the principal supply, constituting a service under heading 9989. Relying on Circular No. 11/11/2017-GST, it held that the service is a composite supply where the printing is the predominant element. It further interpreted the phrase 'relating to' in Sr. No. 66 of Notification No. 12/2017-Central Tax (Rate) broadly, concluding that printing question papers for examinations falls within the scope of services relating to the conduct of examinations by an educational institution.
Provisions relied on
- Section 2(90) of the CGST Act
- Section 97(2) of the CGST/GGST Act
- Notification No. 12/2017-Central Tax (Rate)
- Notification No. 11/2017-Central Tax (Rate)
- Circular No. 11/11/2017-GST
For the practitioner
This ruling confirms that printing question papers for educational institutions is a service and is exempt from GST. It provides a clear distinction between services provided to educational institutions versus other commercial entities. Practitioners can use this to argue for the exemption of similar examination-related printing services, provided the client qualifies as an educational institution.
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/guj.16-2018-19_dt_23.08.18_espl.pdf
Legibility of the scan, as read: high.
Prepared 21-10-2026.
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