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GST update /2026-27/0007

Advance Ruling in case of M/s Codeword Process and Printers

GST UPDATE

Hon’ble Authority: Authority for Advance Ruling (AAR), Karnataka
Applicant: M/s Codeword Process and Printers
Hon’ble Authorities Shri Kalyanam Rajesh Rama Rao (Centre) and Shri Sivakumar S Itagi (State)
Date of Order 16.03.2026
Outcome In favour of the Applicant
 

Brief Facts of the Case

M/s Codeword Process and Printers (hereinafter referred to as “the applicant”) is engaged in the business of providing specialized printing services, primarily involving the printing of confidential examination question papers for universities and educational boards. The activity undertaken by the applicant is executed strictly in accordance with the specifications, format, design, and content supplied by the recipient institutions. The applicant does not exercise any control over the content of the question papers and performs the printing function under strict confidentiality protocols due to the sensitive nature of the documents. The printed materials are used exclusively for conducting examinations by universities. In this backdrop, the applicant approached the Authority for Advance Ruling seeking clarity on the applicability of GST on such services.

Relevant Section / Notification

  • Entry 66(b)(iv) of Notification No. 12/2017-CT
  • Paragraph 2y (ii) of the Notification No. 12/2017

Question before Hon’ble Authority

  • Whether universities fall within the definition of “educational institution” as per paragraph 2y of the Notification No. 12/2017?
  • Whether the activity of printing examination question papers for universities would qualify as a service “relating to the conduct of examination” provided to an educational institution, thereby making it eligible for exemption under Entry 66(b)(iv) of Notification No. 12/2017-Central Tax (Rate)?

Applicants Interpretation

The applicant contended that the printing of question papers is an indispensable and integral component of the examination process, without which the conduct of examinations would not be feasible.
 It was argued that the expression “relating to” used in Entry 66 is of wide amplitude and is intended to encompass not only core examination activities but also ancillary and support services that are intrinsically connected to the examination process.
The applicant further submitted that universities are undisputedly educational institutions as they provide education leading to qualifications recognized by law.

Other AAR Relied Upon

AAR Citation
Orient Press Ltd.  [2019] 106 taxmann.com 240 / (26) (AAR-Mah.) (GST/ARA/89/2018-19/B-23, dated 27.02.2019)
Ashok Kumar Basu (Manali Enterprises) In re [18/WBAAR/18-19, dated 28.09.2018] {2018 (18) G.S.T.L. 49 (AAR-GST)
Hitech Print Systems Ltd., In re [2021] 131 taxmann.com 29 / 88 GST 527 / (55) G.S.T.L. 69 (AAR-AP) {24/AP/GST/2020, dated 15.12.2020)
Management & Computers Consultants In re [2021] 133 taxmann.com 100 / [2022] 89 GST 752 / (60) G.S.T.L. 505 (AAR-WB) {08/WBAAR/2021-22,

Findings and Judgement

Regarding Universities falling in the ambit of ‘Educational Institution’
Upon examination of the Clause 2(y) of the Definitions under Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, as amended, which is defined as follows:
 "Educational Institution" as under: "Educational institution" means an institution providing services by way of, -
i) pre-school education and education up to higher secondary school or equivalent;
( (ii) education as a part of a curriculum for obtaining a qualification recognized by any law for the time being in force;
(iii) education as a part of an approved vocational education course;
 
The Authority addressed the status of universities and concluded that they squarely fall within the definition of “educational institution” as they provide education culminating in qualifications recognized by law and are empowered to prescribe curriculam, conduct examinations, and award recognized degrees under laws such as the University Grants Commission Act, 1956. As the education provided by universities is structured and leads to recognized qualifications, they qualify as “educational institutions” under paragraph 2(y) of Notification No. 12/2017-Central Tax (Rate). Further, Hon’able Karnataka High Court in Rajiv Gandhi University of Health Sciences has held that University is an educational institution for the purpose of exemption notifications. This view has been upheld by the Hon’able Supreme Court also.
Regarding taxability on activity of printing examination question papers for universities by the Applicant
The Authorities carefully analysed the language of Entry No. 66(b)(iv) of Notification No. 12/2017-CT which is reproduced as below:
“Services relating to admission to , or conduct of examination by, such instituition”
It was held that the said notification exempts services provided to educational institutions in relation to admission or conduct of examination. The phrase “relating to” has been interpreted broadly to include not only core activities but also ancillary and incidental services that have a direct nexus with such functions. Since universities are statutory educational institutions required to conduct examinations, activities like printing of question papers being indispensable and integrally connected, qualify as services relating to the conduct of examinations. This position is further supported by Circular No. 151/07/2021-GST dated 17.06.2021, which clarifies that services such as online testing, result publication, and printing of admit cards and question papers are covered under the exemption.
Accordingly, the AAR held that printing of examination question papers by the applicant is exempt from GST under Entry 66(b)(iv).
 

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