The Andhra Pradesh Authority of Advance Ruling (AAR) in the case of Universal Print System vide Advance Ruling order AAR No.07/AP/GST/2022 dated 30.05.2022, has ruled that GST is not payable on the scanning and processing of results of examinations.

The AAR has observed that the printing of pre-examination items like question papers, OMR sheets (Optical Mark Reading), and answer booklets for the conducting of an examination by the educational boards be treated as an exempted supply of service.

The AAR has ruled that printing post-exam items such as marks cards, grade cards, and certificates for educational boards (up to higher secondary) following the scanning of OMR Sheets and data processing in relation to the conduct of an examination is an exempted supply of service.

The applicant, M/s. Universal Print Systems, is in the business of printing, including high-end security printing products since the year 2011. The main products produced by the applicant include Bar Coded OMR Answer Booklets, OMR Sheets, Certificates and Marks Memos, etc; printing of MICR Cheque Books, Fixed Deposit Receipts, Tags and Bonds; and Variable/Digital/Personalized Printing of goods and certificates. 

The applicant claimed that complete end-to-end solutions are provided for the customer right from designing to delivery in mass quantity. The applicant uses the paper and ink as per the approval by the customer in respect of quality as required as per the approved design and delivers the products to specific customers. As such, the products designed and printed as per the requirements of a particular customer can not be delivered to any other person.

The Applicant conducts his business by printing the required material on the printing medium specified by the customers based on the designs provided or approved by the customers. The applicant claimed that the printing activity is combined with security features in many products like cheque books so as to prevent misuse by forgery or replication by unauthorised persons. The applicant is also engaged in printing cheque books, fixed deposit receipts, policy bonds, and seed certificates, which are to be provided by the banks/financial institutions/LIC of India/government seed organisations strictly to their customers. Thus, the activity is also done as per the design/pattern/data being provided by the customer along with the approved size, paper quality, etc.

The applicant has requested an advance ruling on whether the printing of pre- and post-examination items should be treated as exempted supplies of service under Notification No.12/2017-CGST dated 28-6-2017 as amended. Another question raised was whether scanning and processing examination results should be considered an exempted supply of service under Serial Number 66 of Notification No.12/2017-CGST [Rate] dated 28-6-2017 as amended.

The AAR noted that the educational institutions for whom the supplies of the services of printing of examination related materials are made are Andhra University, Visakhapatnam; Satavahana University, Board of Secondary Education, Andhra Pradesh; Krishna University, Board of Higher Secondary Examination, Government of Kerala; and Dr B R Ambedkar Open University. All these institutions invariably fall under the category of “educational institution”. Educational institutions fulfil the criterion of institution providing services by way of education as a part of a curriculum for obtaining a qualification recognised by any law for the time being in force.