Tax Treatment of Printed Trade Advertisement Material on PVC Banners

The case involved determining whether printing content on PVC banners and supplying printed trade advertisement material constitutes a supply of goods. The applicant's transaction was deemed to transfer the title in the printed material, qualifying as a supply of goods under Section 7 of the CGST Act, 2017. The trade advertisement material was classified under HSN code 4911, attracting a tax rate of 12% (CGST 6% + SGST 6%). This classification was supported by relevant notifications and circulars, confirming the tax treatment for such items.

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Issues Involved:
1. Whether the transaction of printing of content provided by the customer on poly Vinyl Chloride banners and supply of such printed trade advertisement material is a supply of goods.
2. Classification of such trade advertisement material if the transaction is a supply of goods.

Issue-Wise Detailed Analysis:

Issue 1: Supply of Goods
The applicant, engaged in printing trade advertising material on PVC, flex, paper, and cloth based on client specifications, queries if this constitutes a supply of goods. The applicant procures raw materials, prints on them as per customer designs, and transfers the title of the printed material to the customer. As per Section 7 of the CGST Act, 2017 read with Schedule-II Sl.No. 1(a), "any transfer of the title in goods is a supply of goods." The applicant's transaction involves transferring the title in the printed material, thus constituting a supply of goods.

Issue 2: Classification of Trade Advertisement Material
The classification of the printed trade advertisement material falls under Notification No.1/2017 - Central Tax (Rate) dated 28.06.2017 under Sl.No.132, HSN code 4911, attracting a tax rate of 12% (CGST 6% + SGST 6%). This classification is supported by Circular No.11/11/2017-GST, which clarifies that printed materials made using physical inputs belonging to the printer are predominantly a supply of goods. Further, the consolidated FAQ under Sl.no 59 confirms that such items fall under HS code 4911 and attract 12% GST.

Summary:
The transaction of printing content provided by the customer on poly Vinyl Chloride banners and supplying such printed trade advertisement material constitutes a supply of goods as per Section 7 of the CGST Act, 2017. The classification of such trade advertisement material is under HSN code 4911, attracting a tax rate of 12% (CGST 6% + SGST 6%).

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