Order Date – 18 August 2022

Facts –

• The Applicant, Anamika Agrawal, is engaged in manufacturing of printed box, mono cartons, labels etc and also undertakes works contract of the same nature. In the process of works contract, the applicant receives only duplex board from its customer on which the applicant undertakes the work of printing, lamination, punching, cutting and other related activities.
• The applicant submits that it has been clarified in Circular 126/45/2019-GST dated 22.11.2019 that job work services supplied to a registered person would attract tax @ 12% and the same would be taxable @ 18% when provided to an unregistered person. 
• The applicant accordingly charges tax @ 12% on job work services provided to registered person and 18% on job work services provided to unregistered persons.

Issues –

• What would be the rate of tax on supply of services for printing on duplex board belonging to the recipient including cutting, punching and lamination of the duplex board, so printed?

Order –

• The authorities observed that Chapter 48 of the Customs Tariff Act specifies ‘Paper and paperboard; articles of paper pulp of paper or of paperboard’. Duplex board, being a form of paper board, falls under this Chapter and attracts tax @ 12% [CGST @ 6% + WBGST @ 6%] vide entry no. 112 of Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017.
• Further, the activities undertaken by the applicant for printing on duplex board belonging to its customer including cutting, punching and lamination, as and when required by the customer, shall be treated as services by way of job work in relation to printing of all goods falling under Chapter 48 where the customer is registered under the GST Act. 
• The AAR also observed that in cases where the customer is not registered under the GST Act, the same shall be treated as services by way of any treatment or process on goods belonging to another person, in relation to printing of all goods falling under Chapter 48. However, in both the cases, the applicable rate of tax would be 12% as specified at items (ia)(b) and (iia) respectively under entry no. 26 of Notification dated 28.06.2017, as amended from time to time.
• Thus, the authorities held that supply of services for printing on duplex board belonging to the recipient including cutting, punching and lamination of the duplex board, so printed, would attract tax @ 12% irrespective of the recipient of the services is registered under the GST Act or not.