Classification of goods— In the instant case, the applicant is engaged in the business of supplying answer booklets/copies to educational institutions.

The applicant has sought advance ruling on classification and nature of the activity of printing of Answer Booklets/ Answer copies and supplying it to Educational Institutions to be used in examinations by using its own raw material consisting of paper, printing ink etc.

The issue to be decided in this case is to whether the activity carried out by him will be treated as a supply of goods or supply of service.

In the instant case applicant is supplying answer booklets/copies with or without OMR having its name logo etc. of his customer and the printing material used in printing of the said items pertains to the applicant. We further observe that the supply of printing to the content as supplied by the recipient of the supply is the ancillary to the principal supply of the answer booklets/copies with or without OMR, therefore the supply will be considered a supply of goods falling under respective heading of chapter 48 or 49 of custom tariff.

Held that— The activity of printing of Answer Booklets/ Answer copies and supplying it to Educational Institutions to be used in examinations by using its own raw material consisting of paper, printing ink etc. is 'Supply of goods' falling under chapter Heading/ Tariff item 4820 of entry 123 of the Schedule II to the notification 01/2017 central tax (Rate) dated 28/06/2017 as amended and chargeable to GST @ 12%.