Classification of service— In the instant case, the applicant is proposing to submit a bid in response to the tender floated by the Karnataka Secondary Education Examination Board for the printing of question papers and other examination materials.

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

i. Whether the activity proposed to be undertaken by the Applicant, of printing stationery items such as question papers, admit cards, answer booklets, SSLC Pass Certificate, the overprinting of variable data and lamination, fail marks cards, Circulars, ID Cards and other formats used for and during examinations, envelopes for packing answer booklets on contract basis for the Karnataka Secondary Education Examinations Board and utilized for the conduct of examinations, would constitute a supply of service to an "educational institution" as defined in Notification 12/2017 CT(R)?

ii. If the answer to the above Question 1 is yes, then whether the service provided to educational institutions, specifically the Karnataka Secondary Education Examinations Board by way of printing of stationery pertaining to the conduct of examination 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?

The Applicant wants to know whether printing of question papers, admit cards, answer booklets, SSLC Pass Certificate, the overprinting of variable data and lamination, fail marks cards, Circulars, ID Cards and other formats used for and during examinations, envelopes for packing answer booklets on contract basis for the Karnataka Secondary Education Examinations Board would constitute a supply of service.

Held that— 

i. (a) The activity proposed to be undertaken by the Applicant, of printing stationery items such as question papers, admit cards, SSLC Pass Certificate, the overprinting of variable data and lamination, fail marks cards, Circulars, ID Cards on contract basis for the Karnataka Secondary Education Examinations Board and utilized for the conduct of examinations, would constitute a supply of service to an "educational institution".

(b) The activity proposed to be undertaken by the Applicant, of printing stationery items such as answer booklets, other formats used for and during examination and envelopes for packing answer booklets on contract basis for the Karnataka Secondary Education Examinations Board and utilized for the conduct of examinations, would constitute a supply of Goods to an "educational institution".

ii. The services provided by the applicant to educational institutions (KSEEB) by way of printing of stationery pertaining to the conduct of examination covered under para i(a) supra is exempted as per entry No.66 (Heading 9992) of Notification No. 12/2017-Central Tax (Rate), dated 28th June, 2017 as amended vide Notification No.02/2018-Central Tax (Rate) dated 25th January, 2018.