Order Date: 31 May 2022

Key Pointers:

• The applicant, Coronation Arts Crafts is engaged in printing the content supplied by the recipient using their own paper and ink and supplies such leaflet products to the recipient, M/s. Hindustan latex Ltd (HLL) a Government of India enterprise, who in turn supply the said leaflet product along with their own manufactured product. 
• The issue is whether manufacture and supply of printed leaflet product on the physical inputs owned by the printer while the matter of printing content being supplied by the recipient is classifiable as supply of goods or supply of services as per the provisions of the GST Act. Further, while supplying such printed leaflet product whether HSN heading under 4901 of GST Tariff Act or SAC Code 9989 is applicable?
• The Authorities observed that the predominant activity is printing the contents of the customer in the required tangible inputs sourced by the applicant as per the requirement of the recipient and going by the clarification, the principal supply in the considered transaction is 'Supply of Service' - in the case at hand, the supply made by the applicant to the recipient is a composite supply with 'Supply of Printing Service' as the Principal Supply.
• For the second issue the authority held that the supply of printing services on paper are classifiable under SAC 998912. The principal supply being the 'Supply of Printing service', the composite supply at hand is classifiable under SAC 998912, taxable @18%.