2018 (6) TMI 38

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.... Applicant's representative heard Sri Parag Kothari, Advocate RULING 1. The Applicant is stated to be printing content supplied by the customers on photographic paper. An Advance Ruling is sought regarding the nature and classification of the activity - whether it is supply of goods or service and whether the activity carried out by the Applicant is taxable under HSN 4911 or SAC 9989. Advan....

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....r are further processed in photographic chemical. This activity from printing to processing is done either with Fuji Frontier Digital Minilab by means of laser exposure or with Durst Theta 76 HS Digital Printer by means of LED exposure, thereby transferring the content from an electronic device to printed material as per the customers' requirements. 3. Supply of printed pictures and photographs....

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....sification concerns pre-printed materials or prints which are supplied as such. It, however, appears from the application and the argument of the Applicant at the time of Personal Hearing that the content of the printed matters referred to above, is not being supplied, but only printing service is being provided to the customers. In other words, the content of the printed matter is specific to ....

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....plicant refers to several judgments, which are claimed to have a bearing on this issue. A careful perusal of the judgments reveals that, most of them do not have any bearing to the instant case. In the case of State of Karnataka etc Vs. M/s PROLAB and Others, and in the case of C.K. Jideesh vs UOI activities of Photo Labs are considered to be "Works Contract". However, the activity of "Printing....