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The HC held that the transactions constitute a composite supply under section 2(30) of the CGST Act, with the predominant element being a supply of services (photographic printing/processing) rather than transfer of goods; title to the digital images remains with the customers and the paper/ink are ancillary. Consequently, tax liability is determined by the principal supply (printing services) under section 8, and the proceedings against the anonymous petitioners were upheld and the petition dismissed. The Court declined to interfere with the impugned assessments, while noting that the petitioners remain free to pursue any available statutory remedies against tax assessments.
The HC held that the transactions constitute a composite supply under section 2(30) of the CGST Act, with the predominant element being a supply of services (photographic printing/processing) rather than transfer of goods; title to the digital images remains with the customers and the paper/ink are ancillary. Consequently, tax liability is determined by the principal supply (printing services) under section 8, and the proceedings against the anonymous petitioners were upheld and the petition dismissed. The Court declined to interfere with the impugned assessments, while noting that the petitioners remain free to pursue any available statutory remedies against tax assessments.
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