Composite supply of printed access cards classified as service under SAC 9989, not as goods, due to dominant service element.

Printed access cards prepared using the printer's own paper, ink and inputs, but with content supplied by the recipient, are treated as a composite supply where the principal supply is the service element. Because the cards also confer use rights and related privileges within the temple precincts, the transaction is not classified as mere printed goods under HSN 4901 10 20. The Karnataka AAR placed reliance on the principal supply test and CBIC guidance on printed materials supplied with recipient-provided content, and classified the supply under SAC 9989 as taxable service.

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Issues: Whether the printed 'access cards' supplied by the applicant, where the contents are provided by the recipient, are classifiable as goods under HSN 4901 10 20 or as a composite supply of services under SAC 9989, and the applicable GST rate.

Analysis: The contents are supplied by the recipient, while the applicant uses its own paper, ink, and other inputs to print the cards. The printed cards are not treated as mere printed matter because the supply includes the right to use the cards for staying and movement within temple precincts, together with other privileges, which makes the transaction a composite supply. Applying the principle of principal supply, the dominant element is the service component and not the supply of goods. The guidance in the CBIC circular on printed materials supplied using the printer's physical inputs supports classification as service where the principal supply is printing content supplied by the recipient. The supply therefore falls under heading 9989 and is taxable at the rate prescribed for that entry.

Conclusion: The printed access cards are classifiable as a supply of service under SAC 9989 and are liable to GST at 9% under CGST, 9% under KGST, and 18% under IGST.

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