Advance Ruling: Mixed Supply of Printing & Intermediary Services Taxable at 18%

The Applicant's procurement of advertisements for the Directory was deemed admissible for an advance ruling. The Authority classified the Applicant's supply as a mixed supply of printing and intermediary services, taxable at 18%. The ruling specified that the Applicant's supply to the Club was considered the supply of intermediary service. The judgment provided a comprehensive analysis of the issues raised, determining the nature of the supply and its taxability under the GST Act.

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Issues:
1. Admissibility of the Application
2. Classification of the Applicant's procurement of advertisements
3. Determination of the nature of the Applicant's supply
4. Taxability of the mixed supply made by the Applicant

Admissibility of the Application:
The Applicant sought a ruling on whether its procurement of advertisements for the Directory is classifiable as selling space for advertisement in print media. The Applicant's supply, acting as an intermediary for procuring advertisements, was considered admissible for an advance ruling under section 97(2) (a) & (b) of the GST Act. The Application was admitted as the issue raised was not pending or decided in any proceedings under the GST Act, and no objection was raised by the revenue officer.

Classification of the Applicant's procurement of advertisements:
The Applicant contended that the Directory, meant for non-commercial purposes, falls under print media as defined in the relevant notification. The Revenue, however, argued that the Applicant's services go beyond mere advertisement space sales. The Authority noted the obligation of the Applicant to finance the project cost based on advertisement proceeds and ruled that the Applicant's supply was not a composite supply but a mixed supply.

Determination of the nature of the Applicant's supply:
The Applicant was found to be making a bundled supply of printing service and intermediary service for selling advertisement space to the Club. This bundled supply, not naturally bundled, was treated as a mixed supply under the GST Act. The Applicant's service of selling space for advertisement was classified under a specific SAC, taxable at 18% under the relevant Rate Notification.

Taxability of the mixed supply made by the Applicant:
The Authority ruled that the Applicant's mixed supply to the Club should be treated as the supply of intermediary service taxable at 18%. It clarified that the Club's supply of selling advertisement space was not considered in the ruling due to the limitation under section 95 to supplies made or intended to be made by the Applicant. The ruling was declared valid subject to the provisions of the GST Act.

In conclusion, the judgment addressed the admissibility of the application, the classification of the Applicant's services, the nature of the supply made, and the taxability of the mixed supply, providing detailed analysis and clarification on each issue raised by the Applicant.

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