Printing on PVC Banners: Supply Classified as Goods and Services

The Appellant's printing of trade advertisement material on polyvinyl chloride banners was deemed a composite supply of goods and services by the WBAAR, with printing considered the predominant element. The printed material was classified under Chapter 39 and 49 of the Tariff Act as ancillary to the principal supply of printing service. Despite referencing conflicting CBIC Circulars and arguing for the classification of their supply as goods, the Appellant failed to convince the court. The judgment upheld the WBAAR's decision, ruling that the supply was primarily a service based on the evidence presented.

---

---

Issues:
- Whether printing of content on polyvinyl chloride banners and supplying such printed trade advertisement material amounts to supply of goods.
- What is the classification of such trade advertisement material under GST Tariff if the transaction is a supply of goods.

Analysis:
1. The Appellant, engaged in printing trade advertisement material, sought an advance ruling on whether their activity amounts to a supply of goods and the classification under GST Tariff.
2. The WBAAR held that the transaction constitutes a composite supply involving both goods and services, with printing being the predominant element. The printed material was deemed to have no utility other than displaying content, classifying it under Chapter 39 and 49 of the Tariff Act as ancillary to the principal supply of printing service.
3. The Appellant challenged the ruling citing the Telangana AAR's decision treating printed trade advertisement as goods, arguing that the printed material falls under the definition of 'goods' in the GST Act.
4. Reference was made to CBIC Circulars supporting both positions, with the Appellant asserting their supply qualifies as goods under a specific subheading in the Tariff Act.
5. The Appellant emphasized their activity as a composite supply where the principal supply is goods, citing relevant sections and classifications to support their claim.
6. The Respondent highlighted the necessity of printing on the PVC material for its utility, supporting the WBAAR's position on the nature of the supply.
7. The judgment analyzed conflicting interpretations of CBIC Circulars, emphasizing the distinction between scenarios where usage rights are owned by the supplier of content and where they are not, to determine the principal supply.
8. It was concluded that the printed material in question had no secondary use beyond displaying content, aligning it more closely with the scenario described in a specific paragraph of the Circular.
9. Samples of the Appellant's products were examined to establish the exclusive ownership of content by customers, leading to the determination that the predominant supply was a service, as per the Circular's classification.
10. Contradictions in the product descriptions on invoices and purchase orders were used to support the finding that the supply was primarily a service, not goods.
11. The appeal was dismissed, upholding the ruling of the WBAAR, as the Appellant failed to establish their supply as goods based on the provided evidence and arguments.

---