Classification of Supply — the applicant, seeking an advance ruling in respect of the following questions.

1. Whether supply of service of:

(i) Printing of Pre-examination items like question papers, OMR sheets (Optical Mark Reading), answer booklets;

(ii) Printing of Post-examination items like marks card, grade card, certificates to the educational boards of up to higher secondary; and

(iii) What would be the classification and the applicable GST rate, for the supply of Printing of cheque book/ railway tickets be treated as exempted supply of service by virtue of Entry No. 66 of the Notification No.12/2017-Central Tax (Rate), dated 28th June, 2017.

Held that—

In respect of question no. 1, As per under Entry No. 66 of the Notification No.12/2017-CT (Rate), dated 28th June, 2017 as amended, services provided to an educational institution, by way of Services relating to admission to, or conduct of examination by, such institution falls under Heading 9992 (Education Services and exempted from payment of GST. Such services are exempted only if they are, in the subject case, related to conduct of examination by such institution.

question papers, OMR sheets (Optical Mark Reading), answer booklets are very essential and necessary requirements to conduct any examination. To print question papers the content i.e. the questions will be provided by the institution conducting the examination.

Hence we find that in the subject case there is a supply of services and since the same are provided to educational institutions, the same shall be classified under Heading 9992 and will be exempted from payment of GST.

In respect of question 2, GST is applicable to all the supplies of goods and services made through the railways, including passenger tickets, commercial transports and catering services. The applicant is claiming exemption on its supply considering the same as ‘Railway Tickets’.

In a situation where the applicant does printing for Railway Tickets and uses physical input i.e. paper supplied by the Railways then the same will be considered as a supply of printing services. This scenario will attract the services under Heading 9988 (iia) i.e. “Services by way of ant treatment or process on goods belonging to another person, in relation to printing of all goods falling under Chapter 48 or 49, which attract CGST@ 6%”

In respect of question no. 3, In case of cheques where the applicant uses their own physical input i.e. paper, then the case is covered under under Heading 9989 (i) of Notification No.11/2017-Central Tax (Rate) dated 28th June, 2017 as amended and is taxable at 6% CGST and where the applicant uses physical input i.e. paper supplied by their client then the same will fall under Heading 9988 (ii(i)(c) and is taxable at 2.5% CGST.—Orient Press Ltd., In Re… [2019] 09 TAXLOK.COM 086 (AAR-Maharashtra)