In a significant ruling on GST exemption, that brings relief to educational service providers, the Tamil Nadu Authority for Advance Rulings (AAR) has clarified that specific services related to examinations, such as printing and result processing offered to educational institutions, are exempt from Goods and Services Tax (GST). This decision was delivered in the case of M/s. Mehra Computer Systems Limited, under Case No. TN/04/ARA/2025 dated 12.02.2025.
โ Background of the Case
The applicant, M/s. Mehra Computer Systems Limited, is engaged in providing various services to educational institutions, including:
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Pre-examination services such as:
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Printing of question papers
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Hall tickets
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OMR sheets
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Answer booklets
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Post-examination services such as:
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Printing of mark sheets
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Degree certificates
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Grade sheets/rank sheets
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OMR-based scanning and result processing
All content for these services is provided by the respective educational institutions, while the applicant supplies the materials and carries out the customized printing and processing.
โ Key Issue Before the AAR
The core issue raised was:
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Whether services like printing of question papers, OMR sheets, hall tickets, mark sheets, and result processing provided to universities and educational boards qualify for GST exemption.
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Whether such services qualify as a composite supply, and what the principal supply is in that case.
๐งพ AAR Ruling & GST Implications
The Tamil Nadu AAR ruled in favor of the applicant, making the following key observations:
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The services provided form a composite supply, with printing of examination materials being the principal component.
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The contracts are not for the sale of paper or stationery, but for customized printing services based on the institutionโs content and specifications.
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Citing Serial No. 66(b)(iv) of Notification No. 12/2017 โ Central Tax (Rate), the AAR confirmed that services relating to admission or conduct of examinations provided to educational institutions are exempt from GST.
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This interpretation is further supported by CBIC Circular No. 151/07/2021-GST, which clarifies that services such as online testing, result publication, and exam-related printing offered to educational boards are eligible for GST exemption.
๐ Conclusion
This ruling brings clarity to service providers working with educational institutions. By categorizing such services as composite supplies related to the conduct of examinations, the AAR has reinforced their eligibility for GST exemption. Educational boards, universities, and affiliated vendors can now operate with better tax compliance and confidence under the current GST framework.
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