Printing services for foreign customer in India subject to GST under SAC 9989

The Applicant's printing activity for a foreign customer was classified as a supply of service under SAC 9989, provided to a recipient in India, resulting in GST liability. Despite the consideration being in US dollars, as purchase orders and invoices were in INR, the activity did not qualify as an export under the IGST Act. Therefore, the Applicant was deemed liable to pay GST on the domestic supply of printing services.

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Issues: Classification of activity as "supply of goods" or "supply of services" and determination of "export" status.

Classification as "supply of goods" or "supply of services":
The Applicant, engaged in printing, sought a ruling on whether procuring orders from a foreign party to print religious texts and deliver them in India constitutes "supply of goods" or "supply of services." The Authority admitted the ruling under section 97(2)(a) of the GST Act. The Applicant's activity was analyzed in light of TRU Clarification, which categorized similar activities as "supply of services" under heading 9989, liable to GST at 12%. The Applicant's role was deemed as providing a composite supply, with printing being the principal supply. The Authority concluded that the Applicant's activity falls under "supply of services" and is subject to GST.

Determination of "export" status:
Although the Applicant's activity could not be ruled as an "export" under the IGST Act due to the recipient being in India, the Applicant claimed consideration in US dollars. However, as purchase orders and invoices were in INR, doubts arose regarding foreign currency payment. This raised concerns about violating conditions under the IGST Act. Consequently, the Applicant's supply was deemed as domestic, making them liable to pay GST. The ruling stated that the Applicant's service of printing Bibles for the foreign customer is classified as a supply of service under SAC 9989, supplied to a recipient in India, and subject to GST in INR.

Conclusion:
The ruling clarified that the Applicant's printing activity for the foreign customer constituted a supply of service under SAC 9989, supplied to a recipient in India, thus attracting GST liability. The decision remains valid unless declared void under the GST Act.

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