Classification of service— In the instant case, the applicant M/s. Karnataka secondary education examination board, is an independent Board with statutory powers established by the Karnataka secondary education examination board Act, 1966 for the purpose of holding and conducting certain public examinations. 

The applicant has sought advance ruling in respect of the following questions:

i. Whether the Applicant is an “educational institution” and ought to be treated as such for the purposes of applicability of GST?

ii. Whether the activity of printing of the following items of stationary on behalf of educational institutions constitutes a supply of service:

a. question papers, b. admit cards, c. answer booklets d. SSLC Pass Certificate, the overprinting of variable data and lamination, e. Fail Marks cards f. Circulars, ID card and other formats used for and during examinations. g. Envelopes for packing answer booklets

If yes, whether the service provided to educational institutions by way of printing of stationery and other services incidental to the conduct of examination by such institutions would be covered by Sr.No.66 (Heading 9992) of Notification No. 12/2017-Central Tax (Rate), as amended and subject to Nil rate of tax.

iii. Whether the following incidental services provided to or performed on behalf of educational institutions are also services that are covered by Sr. No. 66 (Heading 9992) of Notification No. 12/2017-Central Tax (Rate), as amended and subject to Nil rate of tax:

a. scanning of answer booklets and converting the same into digital images; b. hiring of light motor vehicles and heavy motor vehicles for transportation of examination materials; c. annual maintenance of computers and equipment; d. obtaining the services of programmers and technical staff for examination related work; and e. Obtaining Group 'D' staff, Drivers, Data Entry Operators, Security Guards & House Keeping services related for SSLC Examination work.

Karnataka secondary education examination board is an educational institution for the limited purpose of providing services by way of conduct of examination to the students.

The Applicant wants to know whether the activity of printing of question papers, admit cards, answer booklets, SSLC Pass Certificate, Fail Marks cards, etc on behalf of educational institutions constitutes a supply of service. The applicant states that the printing activity is done by third party, which makes the applicant recipient of services and not the supplier of the services.

Held that— In the instant case, we observe that the Applicant, i.e Karnataka secondary education examination board, is not a supplier. Thus the Authority refrains itself from giving any ruling in respect of the same.