Classification of Service— In the instant case, the applicant is proposing to submit a bid in response to the tender floated by the Karnataka Textbook Society (hereinafter referred to as “KTBS”) for the printing of school textbooks as prescribed by the Karnataka State Board.

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

i. Whether KTBS can be classified as “educational institution” for the purposes of applicability of GST on printing services provided to it by the Applicant?

ii. Alternatively, whether KTBS can be classified as “State Government” for the purposes of applicability of GST on printing services provided to it by the Applicant?

iii. Whether the rate of tax being charged at present by the printers on the printing of textbooks supplied to KTBS i.e., @ 12%, is correct or whether any exemptions or lower rate of tax would be applicable on the said contracts for printing and supply of school textbooks.

The Applicant states that they are proposing to submit a bid in response to the tender floated by the Karnataka Textbook Society (hereinafter referred to as KTBS) for the printing of school textbooks as prescribed by the Karnataka State Board and would like to know whether KTBS can be classified as “educational institution” or “State Government” for the purposes of applicability of GST on printing services provided to it by the Applicant.

Held that—

i. KTBS cannot be classified as “educational institution” for the purposes of applicability of GST on printing services provided to it by the Applicant.

ii. KTBS cannot be classified as “State Government” for the purposes of applicability of GST on printing services provided to it by the Applicant.

iii. Rate of tax being charged at present by the printers on the printing of textbooks supplied to KTBS i.e., @ 12%, is incorrect and the same is taxable @ 18% as per entry No. 27 of Notification No.11/2017-Central Tax (Rate) dated: 28.06.2017 further amended vide Notification No.6/ 2021-Central Tax (Rate) dated: 30.09.2021.