2026-VIL-130-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR – Classification of Service and applicable GST rate - Job Work Services - Composite Supply or not - Applicant is engaged in providing offset printing services on Kraft Paper and Duplex Paper supplied by packaging industries and corrugated box manufacturers under delivery challan in accordance with specifications and instructions provided by the principals. Upon completion of offset printing, the processed papers are returned to the principals - Applicable GST rate on the job work services on the job work services of offset printing provided on Kraft Paper and Duplex Paper supplied by the Corrugated box manufacturer or Packaging Industries - Whether the job work services of offset printing on Kraft Paper and Duplex Paper constitute a composite supply - HELD - The activities undertaken by the applicant are interconnected with each other and are naturally bundled and supplied in conjunction with each other in the ordinary course of business. These activities constitute a composite supply as defined under Section 2(30) of the CGST Act, 2017, where offset printing is the principal supply and all pre-offset printing and post-offset printing activities are ancillary to the principal supply of offset printing – As per Section 8(a) of the CGST Act, 2017, a composite supply shall be treated as a supply of the principal supply. Entry 26(ii)(f) of Notification No.11/2017-Central Tax (Rate) specifies that GST rate of 5% is applicable on job work services in relation to printing of goods falling under Chapter 48 or 49 of the Customs Tariff Act, 1975 which attract GST at 5% or NIL - Kraft Paper and Duplex Paper are classifiable under CTH 4804 and 4810 respectively and are chargeable at 18% GST under Notification No.09/2025-Central Tax (Rate) dated 17.09.2025 - Since the job work is performed on goods chargeable at 18% GST and not at 5% or NIL, Entry 26(ii)(f) does not apply. Instead, Entry 26(iv) which covers job work services other than those specified in Entry 26(i), (ii) and (iii) becomes applicable, with GST rate of 18% - Ordered accordingly
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