Composite supply in GST: printed advertising material with no independent use is treated as a printing service, not goods supply.

Supply of printed trade advertisement material was treated as a composite supply under GST because the printed PVC and similar material had no independent utility apart from carrying content supplied by the recipient. Applying the dominant nature test and the principal supply concept, the Authority found printing to be the substantive element and the printed goods merely ancillary. The classification scheme for printing services, including the treatment of goods under Chapters 48 and 49, supported this view. The transaction was therefore characterised as a taxable printing service rather than a supply of goods.

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Issues: Whether the supply of printed trade advertisement material is a composite supply in which printing is the principal supply and the printed material is only ancillary.

Analysis: The supply consisted of printing on PVC and similar material using content supplied by the recipient. The contract was treated as a composite supply under the GST framework, and the relevant inquiry was whether the substance of the transaction showed separate rights in the goods or whether the printed material had utility only as a carrier of the printed matter. The Authority applied the dominant nature test and the concept of principal supply, noting that the printed advertising material had no use apart from displaying the printed content. It also relied on the GST classification scheme for printing services and the treatment of goods falling under Chapters 48 and 49 of the tariff.

Conclusion: The supply was held to be a composite supply in which printing is the principal supply and the printed goods are ancillary.

Final Conclusion: The ruling classifies the transaction as a taxable printing service rather than a goods supply for GST purposes.

Ratio Decidendi: Where printed advertising material has no independent utility apart from carrying the printed content supplied by the recipient, the transaction is a composite supply and printing constitutes the principal supply.

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