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The activity of printing of question papers by the applicant is activity of supply of services classifiable under Heading 9989 of the scheme of classification of services.

Classification of Supply — The Applicant in his application sought clarification and Advance Ruling as follows :-

(a) Whether activity of printing of question papers on behalf of educational institutions can be classified as activity of supply of goods or supply of services?

(b) If it is supply of services, referring to Sr.No.27 of Notification No. 11/2017-C.T. (R), dated 28-6-2017 as amended by Notification No.31/2017-C.T. (R), dated 13-10-2017, then benefit of S. No. 66 of Notification No.12/2017-C.T. (R), dated 28-6-2017 is allowable as amended by Notification No. 2/2018-C.T. (R), dated 25-1-2018; or

(c) If it is supply of goods, then question paper should be treated as exempted goods at S. No. 119 of exempted list at NIL rate of tax under chapter heading/sub-heading of 4901 10 10 of "printed books including Braille books"; or

(d) It should be covered by Schedule I at S.No.201 liable to tax at 2.5 CGST under "brochures, leaflets and similar printed matter, whether or not is single sheets".

Question 1 :- The activity of printing of question papers by the applicant is activity of supply of services classifiable under Heading 9989 of the scheme of classification of services.

Question 2 :- The benefit of Sr. No. 66 of Notification No. 12/2017-Central Tax (Rate) is admissible only in case where service is provided to an educational institution [(as defined in clause (y) of Paragraph 2 of the Notification No. 12/2017-Central Tax (Rate)]. The services of printing of question paper, supplied by the applicant to other than 'educational institutions' will be covered by Sr. No. 27(i) of Notification No. 11/2017-Central Tax (Rate), as amended, and will attract Goods and Services Tax @ 12% (CGST 6% + SGST 6% or IGST 12%).

Question 3 :- No, it is not supply of goods. 

Question 4 :- Fourth question raised by the applicant is applicable only when third question is affirmative i.e., activity of printing of question papers on behalf of educational institutions is considered as supply of goods, as the answer to the third question is negative, hence fourth question is not applicable. — Maxwell Co. Pvt. Ltd., In Re… [2019] 13 TAXLOK.COM 096 (AAR-UP)