2026-VIL-160-AAR
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SGST Advance Ruling Authority

GST – Kerala AAR - Classification of Printing Service as Job Work - Printing Activity on Customer-Supplied Materials - Applicant engaged in printing services on paper and content supplied by customer using printer's own consumables, sought classification under SAC 9988 - Whether activity of printing on customer-supplied paper and content constitutes job work within meaning of Section 2(68) of CGST Act, 2017 - HELD - Printing activity undertaken on customer-supplied paper and content using printer's own consumables is classifiable under Heading 9988 as manufacturing services on physical inputs owned by others. However, characterization as job work within definition of Section 2(68) depends on whether recipient of services is registered person under GST - Job work requires treatment or process on goods belonging to another registered person. Where customer is unregistered person, activity constitutes services by way of treatment or process on goods belonging to another person but not job work as strictly defined – The activity would be considered as Job Work only if the customer/recipient of such services provided by the applicant is registered under GST. In other cases, it would be classified as services by way of any treatment or process on goods belonging to another person – Ordered accordingly - Concessional Rate Applicability for Printing Services - GST Rate for Printing of Goods under Chapters 48 and 49 - Applicant sought confirmation whether printing services on customer-supplied materials qualify for concessional rate of 5% under Entry No. 26 of Notification No. 11/2017-CT(R) when printed goods fall under Chapters 48 or 49 - Whether printing services related to goods under Chapters 48 or 49 are eligible for 5% or standard 18% rate - HELD - Printing services classifiable under Heading 9988 are eligible for concessional rate of 5% only when services fall within specific sub-entries of Entry 26 namely sub-entries (ii)(e), (ii)(f), (v)(a) and (v)(b). Sub-entry (ii)(e) covers job work for printing of newspapers, books including Braille books, journals and periodicals. Sub-entry (ii)(f) covers job work for printing of all goods falling under Chapters 48 or 49 attracting central tax at 2.5% or Nil. Corresponding sub-entries (v)(a) and (v)(b) apply to services by way of treatment or process on goods of unregistered persons. Concessional rate benefit restricted to goods under Chapters 48 or 49 which themselves attract central tax at 2.5% or Nil rate. In all other cases where printing does not fall within specified categories, GST payable at standard rate of 18% under residual sub-entries (iv) and (vii). Applicability of concessional rate depends on actual tariff classification and tax rate of printed output - Printing of Religious Books - Supply of Service or Supply of Goods - Applicant engaged in printing of religious texts and extracts where content provided by customer or sourced from public domain and paper and consumables supplied by printer - Whether printing of religious books with customer-supplied content and printer-supplied materials is supply of goods or service and applicable rate - HELD - Printing of religious texts or extracts where content supplied by customer or sourced from public domain and materials supplied by printer constitutes composite supply of services with principal supply being printing service. Supplies of paper and consumables are ancillary to principal supply of printing service. Applying principles of composite supply under Section 8 read with Sections 2(30) and 2(90) of CGST Act, taxability determined by nature of principal supply - Circular No. 11/11/2017-GST dated 20.10.2017 establishes that where content supplied by publisher or person owning usage rights and printer uses own physical inputs including paper, principal supply is printing service while supply of materials ancillary. Applicant executing customer-specific printing orders rather than independently publishing books on own account. Distinctive factor is whether printer independently publishing and supplying books or merely executing customer-directed printing orders - Activity classifiable as supply of printing service under SAC 9989 taxable at 18% under Entry 27(ii) of Notification 11/2017. Fact that printed material consists of religious books or extracts irrelevant to characterization. Benefit of Nil or concessional rate applicable to printed books cannot extend merely because output in book form or contains religious literature.
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