GST classification of printed products depends on dominant nature; books were goods, calendar was a service, exemption denied

GST classification turns on the true nature of the transaction and its dominant element. Printing and supply of text books and notebooks, where the supplier used its own inputs and the copyright arrangement was only temporary, was treated as supply of goods, because the printed products remained the essential output. Printing and supply of the bilingual parental calendar was treated as supply of services, as the transaction was a composite supply with printing as the principal supply and materials ancillary. Supply of the comprehensive progress report card was not exempt, because the recipient was the Education Department and the conditions for the cited notification entries were not satisfied.

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Issues: (i) Whether printing and supply of text books and notebooks under the contract amounted to supply of goods or supply of services; (ii) Whether printing and supply of the bilingual parental calendar amounted to supply of goods or supply of services; (iii) Whether printing and supply of the comprehensive progress report card to the Education Department, Government of Assam attracted exemption under the relevant notification entries.

Issue (i): Whether printing and supply of text books and notebooks under the contract amounted to supply of goods or supply of services.

Analysis: The contract showed that the applicant printed the books and notebooks on its own account using its own inputs, while the temporary copyright arrangement did not alter the essential character of the transaction. The supply was not treated as a mere printing job for another person, and the presence of copyright rights was not sufficient to convert the transaction into a service. For the notebooks also, the recipient supplied the content and the applicant undertook printing with its own materials, so the dominant element remained supply of the finished printed goods.

Conclusion: The printing and supply of text books and notebooks were held to be supply of goods.

Issue (ii): Whether printing and supply of the bilingual parental calendar amounted to supply of goods or supply of services.

Analysis: The calendar, though designed for educational use, retained the basic character of a calendar. The recipient supplied the content and the applicant performed the printing work using paper and ink purchased by it. The transaction was therefore a composite supply in which printing was the principal supply and the physical materials were ancillary.

Conclusion: The printing and supply of the bilingual parental calendar were held to be supply of services.

Issue (iii): Whether printing and supply of the comprehensive progress report card to the Education Department, Government of Assam attracted exemption under the relevant notification entries.

Analysis: The report card supply was treated as a service relating to conduct of examination, but the recipient was the Education Department and not an educational institution within the meaning of the exemption entry. The conditions for exemption under Serial No. 3 or 3A were not satisfied, and the value of goods involved was not established to bring the supply within the composite-supply threshold.

Conclusion: The supply was not held to be exempt under the cited notification entries.

Final Conclusion: The ruling classified different printed products according to their dominant nature, treating the books and notebooks as goods, the calendar as a service, and declining exemption for the progress report card supply.

Ratio Decidendi: Classification under GST depends on the true nature of the supply and the dominant element of the transaction, and a temporary copyright arrangement does not by itself convert a printed output supplied on the supplier's own account into a service.

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