Classification of goods— In the instant case, the appellant is engaged in the activity of printing leaflets falling under CHS No. 4901, the said product is manufactured out of the inputs namely paper/ink owned by the appellants and content supplied by the clients mainly located in the pharmaceutical sector.

The moot issue to be decided by us is to ascertain the classification of the supply made by the appellant. The basic transaction between the appellant (supplier) and the clients (recipient) is that the client (mostly from the pharmaceutical sector) approaches the appellant (supplier) with the content/instructions that is required to be printed in the form of leaflet.

The paper and the ink used in printing is owned by the appellant. The transaction is considered to be completed only when the desired content/instructions is printed in the desired format by the appellant (supplier) and handed over to the customer. Thus, in this transaction. there is an element of supply of goods as well as supply of service. The appellant is also on record to accept that in the instant case there is a supply which comprises of goods as well as that of service.

The appellant in the grounds of appeal has argued that supply of leaflet although treated as mixed supply as per Section 2(74) of the CGST Act. 2017 has to be treated as supply of goods in accordance with the Section 8(a) of the CGST Act. 2017 as per which in case of composite supply comprising of two or more supply. one of which is a principal supply has to be treated as supply of such principal supply.

Held that— The classification of goods or services cannot be made merely on the ground that classifying their supply in a particular manner will deprive them from other benefits. Hence, we refrain from making any comments on the practical difficulties presented by them. we do not find any reason to interfere with the order of the Advance Ruling Authority. This appeal is disposed off accordingly.