Classification of service— In the instant case, the applicant have sought Advance Ruling on the following question:

1. 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 GST Act.

2. While supplying such printed leaflet product whether HSN heading under 4901 of GST Tariff Act or SAC code 9989 is applicable.

3. Determination of tax liability payable on such printed leaflet product supplied as above.

The facts of the case available before us is that the applicant 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. It is also informed that the leaflet product is supplied by their unit to the said customer charging 12% IGST under SAC heading 9989 of GST Tariff Act 2017.

The applicant has stated that the Purchase Order is issued to them based on the Price bid submitted by them and they have furnished copies of the Price bids furnished by them, Purchase Orders issued to them by M/s. HLL and the Price bids submitted by other persons to HLL. The applicant has informed that some other suppliers are supplying such printed leaflet product charging 5% IGST classifying the same as supply of goods under Chapter heading 4901 of GST Tariff Act 2017.

Held that— 

1. The printing of content provided by the recipient on the paper & materials of the applicant and supply of such printed leaflets to the recipient is a composite supply as defined under Section 2(30) of the CGST/TNGST Act 2017 with 'Supply of service of printing' as the principal supply.

2. The applicable classification code for the said supply is SAC 9989.

3. The applicable rate of tax effective from 1st October 2021 is CGST @9% as per SI.No.27 of Notification No. 11/2017 CT(Rate) Dated 28.06.2017 as amended and SGST @9% as per SI.No. 27 of Notification G.O. (Ms) No. 72 dated 29.06.2017 No.II(2)/CTR/532(d-14) as amended.