GST classification of printing distinguishes customer-material processing from printer-supplied religious-book orders, determining concessional eligibility and standard-rate service treatment.
Printing performed on customer-supplied paper and content falls under Heading 9988; it constitutes job work only where the owner of the goods is GST registered, but remains a treatment or process on another person's goods otherwise. The 5% GST rate applies only to specified printing of newspapers, books, journals, periodicals and qualifying Chapter 48 or 49 goods; other Heading 9988 printing attracts 18%. Printing religious books using the printer's own paper and consumables is a composite supply with printing as the principal supply, classifiable under Heading 9989 and taxable at 18%, rather than a supply of books eligible for NIL or concessional GST.
Issues: (i) Whether customer-supplied paper and content printed with the printer's consumables are classifiable under Heading 9988 and constitute job work; (ii) Whether such Heading 9988 printing qualifies for the 5% GST rate under Entry No. 26; (iii) Whether printing religious books using the printer's paper and consumables is a supply of goods eligible for NIL or concessional GST or a printing service.
Issue (i): Whether customer-supplied paper and content printed with the printer's consumables are classifiable under Heading 9988 and constitute job work.
Analysis: Section 2(68) requires a treatment or process on goods belonging to another registered person for the activity to be job work. Where the customer supplies the paper and content, ownership of the paper and printed output remains with the customer. The printing activity is a treatment or process on goods owned by another and falls under Heading 9988 irrespective of the recipient's registration status; registration determines whether it is termed job work.
Conclusion: The activity is classifiable under Heading 9988; it is job work only where the recipient is GST registered, and otherwise is a treatment or process on goods belonging to another person. In favour of Assessee to that extent.
Issue (ii): Whether such Heading 9988 printing qualifies for the 5% GST rate under Entry No. 26.
Analysis: Items (ii) and (v) of Entry No. 26 prescribe the concessional rate for printing newspapers, books, journals and periodicals, and for printing goods under Chapters 48 or 49 that themselves attract central tax at 2.5% or NIL. The benefit applies both to job work and to treatment or process not qualifying as job work. Items (iv) and (vii) are residual entries taxable at 18%.
Conclusion: The 5% rate applies only to printing covered by the specified concessional sub-entries; all other Heading 9988 printing is taxable at 18%. Partly in favour of Assessee.
Issue (iii): Whether printing religious books using the printer's paper and consumables is a supply of goods eligible for NIL or concessional GST or a printing service.
Analysis: Paper, consumables and printing are naturally bundled supplies. Under Sections 2(30), 2(90) and 8, printing is the principal supply where identified content is supplied by the customer or selected from the public domain for a customer-specific order, while physical inputs are ancillary. The nature of the religious content does not alter the classification. Circular No. 11/11/2017-GST treats such arrangements as printing services rather than an independent publication and sale of books.
Conclusion: The activity is a composite supply whose principal supply is printing service, classifiable under Heading 9989 and taxable at 18%; it is not a supply of Chapter 49 goods and is not eligible for NIL or concessional GST as such. Against Assessee.
Final Conclusion: Customer-owned material printing is taxable under Heading 9988 at the rate determined by the applicable specific or residual entry, whereas religious-book orders using the printer's own paper and consumables are taxable as printing services.