The Uttar Pradesh Authority for Advance Ruling (AAR) has held that the printing of question papers and other examination-related materials supplied to educational institutions is covered by the GST exemption available to educational services, provided the activities are undertaken as part of a curriculum for obtaining a qualification recognised by law.
The applicant/assessee is engaged in printing and processing examination-related materials for educational boards, universities and other educational institutions.
Buy Now: 70+ Judgements Indirect Tax – July 2026 | E-Magazine
The central legal issue before the Authority was whether the printing and related processing of examination materials—including question papers, OMR sheets, answer booklets, hall tickets, rank cards, marks cards and certificates—could be treated as part of exempt educational services under the GST law. The AAR answered the questions in favour of exemption.
The applicant was engaged or proposed to be engaged in the printing of pre-examination material such as question papers, OMR sheets, answer booklets, hall tickets and other examination material for various educational boards, universities and educational institutions.
The applicant explained that its operations involved not merely printing but also evaluation-related activities, including scanning and processing the results of examinations. According to the statement of facts recorded in the ruling, the applicant’s customers included government bodies as well as educational institutions and universities.
The applicant also stated that it undertook work involving composition, printing and supply of sealed question papers to educational institutions. It was specifically submitted that the question papers were supplied to the institution conducting the examination and were not ordinary marketable commodities meant for sale to the general public.
The applicant sought a ruling on five questions.
The first was whether the printing of question papers on behalf of educational institutions could be classified as a supply of goods or a supply of services.
The second concerned the printing of pre-examination material, including question papers, OMR sheets, answer booklets, hall tickets and other examination material, and whether such supplies were exempt from GST.
The third dealt with the printing of post-examination material, including rank cards, marks cards, grade sheets and certificates, supplied to educational boards and universities, and whether those supplies were exempt.
The fourth concerned the applicant’s activity of scanning and processing OMRs and examination results and whether such activity was covered by the GST exemption applicable to educational services.
The fifth question sought the applicable GST rate and HSN/SAC classification in the event that the activities were not exempt.
A significant part of the applicant’s argument was that the physical inputs used in printing did not determine the true nature of the transaction.
The applicant pointed out that the manuscript material for question papers was owned by the educational boards or universities, while the physical inputs used for printing were supplied by the applicant. According to the applicant, the overall activity consisted of printing as the principal supply, rather than a sale of printed goods as independent commercial commodities.
The applicant relied upon the concept of composite supply under Section 2(30) of the CGST Act, 2017, contending that the supply of printing was the principal supply and that the activity should consequently be examined according to the nature of that principal supply.
The applicant also relied upon CBIC Circular No. 11/11/2017-GST dated October 20, 2017, particularly the clarification concerning printing contracts where the content is supplied by the recipient and the printer provides the physical inputs and printing services.
The applicant further relied upon Notification No. 12/2017-Central Tax (Rate), particularly the exemption for services provided by educational institutions.
The ruling records the relevant exemption framework under which services relating to admission to, or conduct of examination by, an educational institution are covered. The Authority also considered the definition of an “educational institution” contained in the exemption notification.
The applicant’s case was essentially that examination materials such as question papers, answer booklets, OMR sheets and related documents were directly connected with the conduct of examinations and therefore formed part of the educational activity contemplated by the exemption.
Before examining the substantive GST issue, the AAR referred to the statutory scope of an advance ruling under the CGST Act.
The Authority noted that an advance ruling may determine specified questions concerning, among other things, the classification of goods or services, the applicability of a notification issued under the GST law, and the determination of liability to pay tax.
The AAR also referred to Section 104 of the CGST Act concerning situations in which an advance ruling may subsequently be declared void where it is found to have been obtained through fraud or suppression of material facts.
Having considered the application, the personal hearing and the material placed before it, the Authority proceeded to determine the questions raised by Nirmala Press.
A crucial aspect of the ruling was the distinction between ordinary commercial printing and printing undertaken as an integral component of an educational or examination process.
The AAR considered the nature of the materials being printed. These included question papers, OMR sheets, answer booklets, hall tickets, rank cards, marks cards, grade sheets and certificates. The materials were prepared specifically for educational boards, universities and educational institutions and were connected with examinations or educational qualifications.
The ruling also considered the situation where the recipient provides the content while the printer undertakes the physical printing using its own materials. The Authority referred to the CBIC clarification concerning composite supplies of printing services and supplies of printed material.
On the first question, the Authority ruled that the printing of question papers on behalf of educational institutions is exempt where it forms part of the provision of education leading to a qualification recognised by law.
The ruling specifically records the conclusion that such activity falls within the exemption for provision of education where the education forms part of a curriculum for obtaining a qualification recognised by law.
This finding is important because the Authority did not treat the transaction merely as a conventional printing contract. Instead, the nature and purpose of the activity were considered in the context of the underlying educational service.
The AAR separately considered the printing of pre-examination materials such as question papers, OMR sheets, answer booklets and hall tickets.
The Authority ruled that these activities were exempt from GST where they were connected with education forming part of a curriculum for obtaining a qualification recognised by law.
The finding covers a range of examination materials rather than being confined exclusively to the printing of question papers.
The Authority also addressed the printing of rank cards, marks cards, grade sheets and certificates supplied to educational boards and universities.
These activities were likewise held to be exempt from GST when undertaken in connection with education forming part of a curriculum for obtaining a qualification recognised by law.
The ruling therefore extends its treatment beyond the examination-taking stage to documents generated as part of the post-examination process.
Another important issue concerned the applicant’s activity of scanning OMR sheets and processing examination results.
The Authority held that this activity too was covered by the exemption where it related to education forming part of a curriculum for obtaining a qualification recognised by law.
The finding is significant because the activity is not limited to physical printing. It encompasses examination-related processing connected with the administration and completion of educational examinations.
The applicant had also asked the Authority to determine the applicable GST rate and HSN/SAC classification if the activities were found not to be exempt.
However, after holding the activities covered by the exemption, the Authority concluded that the fifth question did not survive for consideration. The ruling records that, since the activities were exempt under Notification No. 12/2017-Central Tax (Rate) dated June 28, 2017, the question concerning the applicable rate and HSN/SAC code became irrelevant in the circumstances.
The Uttar Pradesh AAR unanimously ruled as follows:
- Printing of question papers on behalf of educational institutions: Exempt from GST when covered by the relevant educational exemption.
- Printing of pre-examination materials: Exempt from GST.
- Printing of post-examination materials: Exempt from GST.
- Scanning and processing of OMR sheets and examination results: Exempt from GST.
- GST rate and HSN/SAC classification: The question became irrelevant because the activities were held exempt.
Membership Required to Access Case Details & Order Copy
To view the complete Case Details and Download Order Copy, you must have an active membership. Please subscribe to continue.
