GST Exemption for Educational Slates and Job Work Rules
- Ruling
- ADVANCE RULING NO. GUJ/GAAR/R/2018/12 dated 30.07.2018
- 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
Raja Slates Pvt. Ltd. asked the Gujarat Authority for Advance Ruling (GAAR) if their teachers' and students' slates qualify for a Goods and Services Tax (GST) exemption. They also wanted to know if they must pay tax on job work services used to make these tax-free items.
What has changed
How it worked before
Businesses were often unsure if minor design differences between teachers' and students' slates would change their tax status. Many assumed that if a final product was exempt from tax, the services used to create it would also be exempt from tax obligations.
What has changed
The authority confirmed that both types of slates fall under Tariff Heading 96.10 and are exempt from GST. However, it clarified that job work is a separate service, meaning you must pay tax under the Reverse Charge Mechanism (RCM) if you hire an unregistered person to perform this work.
Who this affects
This ruling is relevant for manufacturers of educational supplies and businesses that outsource parts of their production process to unregistered job workers.
What you should do
You should review your current job work contracts to see if you are using unregistered suppliers, as you may be liable for tax under RCM. Remember that an advance ruling only binds the company that requested it and their specific tax office, so you cannot automatically apply this decision to your own business without professional advice.
The ruling in detail
Authority for Advance Ruling
M/s. Raja Slates Pvt. Ltd.
ADVANCE RULING NO. GUJ/GAAR/R/2018/12 dated 30.07.2018 · Gujarat
Questions before the authority
- Classification of Teachers' Slate and Students' Slate
- Applicability of GST exemption on Teachers' Slate
- Applicability of Reverse Charge Mechanism on job work for tax-free goods
Facts
The applicant manufactures and supplies 'Teachers' Slate' and 'Students' Slate' for educational purposes under orders from the Gujarat Council of Elementary Education. They sought a ruling on the classification and taxability of these items, as well as the tax liability on job work services received for these products. The applicant argued that both types of slates should be treated as tax-free.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification | Tariff Heading 96.10 Classified as slates and boards with writing or drawing surfaces |
| Tax Rate | Exempt Eligible for exemption under Notification No. 2/2017-Central Tax (Rate) |
| Job Work | Taxable Subject to RCM under Section 9(4) of the CGST/GGST Act |
The authority held that both 'Teachers' Slate' and 'Students' Slate' are classifiable under Tariff Heading 96.10 and are eligible for GST exemption. Regarding job work, the authority ruled that manufacturing services on physical inputs owned by others constitute a supply of services, and tax is payable under the Reverse Charge Mechanism when received from an unregistered supplier.
Reasoning
The authority applied the common parlance test to determine that both products are 'slates' and thus fall under the exemption provided by Notification No. 2/2017-Central Tax (Rate). It relied on the Harmonised System of Nomenclature (HSN) Explanatory Notes for Heading 96.10 to confirm the classification. For job work, it cited Schedule II of the CGST Act, which defines such processes as a supply of services, and Section 9(4) regarding the liability of a registered recipient to pay tax on services received from an unregistered supplier.
Provisions relied on
- Section 9(4) of the CGST Act, 2017
- Section 9(4) of the GGST Act, 2017
- Schedule II of the CGST Act, 2017
- Notification No. 1/2017-Central Tax (Rate)
- Notification No. 2/2017-Central Tax (Rate)
- Tariff Heading 96.10
For the practitioner
This ruling confirms that educational slates, regardless of size or minor design differences, are **exempt from GST** under HSN 9610. It serves as a reminder that even if the final product is tax-exempt, **job work services** performed on those goods remain a taxable supply of services. Practitioners should note that the RCM liability for unregistered job workers remains applicable unless a specific exemption is available.
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.12-2018-19_dt_30.07.18_rspl.pdf
Legibility of the scan, as read: high.
Prepared 21-10-2026.
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