Digital image printing classified as photographic processing, with GST treatment based on the specific service code.

Colour printing of customer-supplied images from digital media was classified as photographic and videographic processing services under Service Classification Code 998386, not as ordinary printing and reproduction under 998912. The AAR applied the specific entry for photographic processing, noting that colour printing of images from film or digital media, including output on glossy coated paper or photo paper, falls within that classification. As a result, the activity was treated as taxable under the applicable GST rate for 998386.

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Issues: Whether the applicant's high-quality digital printing of customer-supplied images and pictures falls within the scope of printing of pictures under Circular No. 84/03/2019-GST or within Service Classification Code 998386.

Analysis: The activity involved printing on the basis of content supplied by customers, including high-quality photo prints using digital technology. The relevant service classifications were examined, and Service Classification Code 998912 was held to cover ordinary printing and reproduction services, while Service Classification Code 998386 specifically includes photographic and videographic processing services, including colour printing of images from film or digital media. The Circular clarified that printing of pictures falls under Service Classification Code 998386 and not under 998912. On that basis, printing of images from digital media on glossy coated paper or photo paper was treated as covered by the photographic processing entry.

Conclusion: The applicant's service of colour printing of images from digital media falls under Service Classification Code 998386 and is taxable at 18%.

Final Conclusion: The ruling classifies the impugned printing activity as photographic and videographic processing services rather than ordinary printing and thereby fixes the applicable GST treatment accordingly.

Ratio Decidendi: Where the service specifically involves colour printing of images from digital media, the specific classification for photographic and videographic processing prevails over the general printing and reproduction entry.

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