GST classification of printed material turns on content ownership: supply of goods when supplier owns content, taxable printing service otherwise.

Under GST, the tax treatment of printed material depends on whether the supplier owns the content or merely prints customer-supplied content. Where the applicant owns the content and supplies printed books, textbooks and similar publications, the activity is treated as supply of goods under HSN 4901 and, in the case of printed books, is exempt under the relevant notification. Where the content is supplied by the customer, the principal supply is printing, classifiable as a service under SAC 9989 and taxable at 18%. On the facts, the activity was also held not to be job work because the recipient did not supply the physical inputs needed for that characterisation.

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Issues: (i) Whether printing and supply of books, textbooks, large-print books, online admission booklets, open-sale publications and special-edition books where the content is owned by the applicant or by the customer constitutes supply of goods or supply of services, and the tax consequence thereof; (ii) whether printing activity where the content is supplied by the recipient is a job work service or a printing service under GST.

Issue (i): Whether printing and supply of books, textbooks, large-print books, online admission booklets, open-sale publications and special-edition books where the content is owned by the applicant or by the customer constitutes supply of goods or supply of services, and the tax consequence thereof.

Analysis: The ruling applied the CBIC clarification on printing contracts and the scheme of classification of goods and services. Where the applicant owns the content and supplies printed books, the activity is treated as supply of goods falling under HSN 4901 and, in the case of printed books, is exempt under the relevant exemption notification. Where the content is not owned by the applicant and is supplied by the customer, the dominant supply is printing, which is classifiable as a service under SAC 9989 and taxable at 18%.

Conclusion: The supply is goods and exempt when the applicant owns the content, but it is a taxable service when the content is supplied by the customer.

Issue (ii): Whether printing activity where the content is supplied by the recipient is a job work service or a printing service under GST.

Analysis: Job work requires treatment or process on goods belonging to another registered person and presupposes that the goods, including relevant inputs, belong to the recipient. On the facts, the applicant did not establish that the recipient supplied the physical inputs necessary to characterise the activity as job work. The activity was therefore treated as printing service under the classification for publishing, printing and reproduction services.

Conclusion: The activity is not job work on the facts found and is taxable as printing service under SAC 9989.

Final Conclusion: The ruling draws a distinction between printed books owned by the applicant, which are treated as exempt goods, and printing undertaken on customer-supplied content, which is treated as a taxable service.

Ratio Decidendi: In GST, the tax treatment of printed material depends on whether the applicant owns the content and supplies finished printed books as goods, or merely performs printing on content supplied by the recipient, in which case the principal supply is printing service.

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