
Case Details: In re: Mehra Computer Systems Ltd. (2025) 30 Centax 12 (A.A.R.-GST-T.N.)
Judiciary and Counsel Details
- S/Shri Balakrishna S & B. Suseel Kumar, Members
Facts of the Case
The applicant, engaged in the business of high-end security printing, was providing end-to-end services to educational institutions, including design, printing, and delivery of confidential examination-related materials. These services included the printing of pre-examination items like question papers, hall tickets, OMR sheets, and answer booklets, as well as post-examination items such as mark sheets, degree certificates, grade sheets, and rank cards. The applicant approached the Tamil Nadu Authority for Advance Ruling (AAR) seeking clarity on whether such services qualified as exempt supplies under GST. It was submitted that the services were in relation to the conduct of examinations and should fall within the scope of educational services under Heading 9992, thereby eligible for exemption under Sl. No. 66 of Notification No. 12/2017–Central Tax (Rate), dated 28-06-2017.
AAR Held
The Hon’ble Tamil Nadu Authority for Advance Ruling held that the applicant’s services qualified as exempt supplies under GST. It was held that the printing of pre-examination materials such as question papers, hall tickets, OMR sheets, and answer booklets, when provided to educational institutions for use in examinations, constituted exempt services under Sl. No. 66 of Notification No. 12/2017–Central Tax (Rate), dated 28-06-2017.
Likewise, the printing of post-examination materials including mark sheets, certificates, and rank cards, and services such as scanning of OMR sheets and processing of results for educational institutions, were also treated as exempt supplies. The AAR concluded that all such services, being directly linked to the conduct of examinations by educational institutions, fell within the ambit of Heading 9992 and qualified for exemption under Section 11 of the CGST Act and the corresponding provisions of the Tamil Nadu GST Act.
List of Circulars and Notifications Cited
- Sl. No. 66 of Notification No. 12/2017-Central Tax(Rate), dated 28-6-2017 as amended by Notification No. 2/2018-Central Tax(Rate), dated 25-1-2018
- Circular No. 151/07/2021-GST, dated 17-6-2021
- Circular No. 11/11/2017-GST, dated 20-10-2017