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AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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2022 (9) TMI 369

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....vices Tax Act, 2017, within a period of thirty days from the date of communication of this Ruling, or within such further time as mentioned in the proviso to Section 100 (2) of the GST Act. Every such appeal shall be filed in accordance with Section 100 (3) of the GST Act and the Rules prescribed thereunder, and the Regulations prescribed by the West Bengal Authority for Advance Ruling Regulations, 2018. 1.1 At the outset, we would like to make it clear that the provisions of the Central Goods and Services Tax Act, 2017 (the CGST Act, for short) and the West Bengal Goods and Services Tax Act, 2017 (the WBGST Act, for short) have the same provisions in like matter except for certain provisions. Therefore, unless a mention is specifical....

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....tatement describing the 'Business Process' carried out by the applicant as follows: • Job Work: Preparation of printed box/printed sheets from duplex board. • Material received from customer: Duplex board • Materials used/supplied by the applicant in the process: Printing ink, gum, PVC film, chemical etc. • Main activity: Printing on duplex board • Ancillary activity: Cutting, punching, lamination etc.(if required by the customer) • Design and specification: It is provided by the customer. • Brief description: The applicant prints the design and content on duplex board supplied to him by its customer. Further, the applicant provides services in the na....

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....ide the applicable tax rate on such supply provided by the applicant. 4.2 To determine the applicable rate of tax on such supply, we first need to decide whether such activities would be regarded as supply of goods or supply of services. Entry No. 3 of Schedule II of the GST Act classifies any treatment or process which is applied to another person's goods as a supply of services. It is an admitted fact that the applicant carries out printing works on goods (duplex board for the instant case) owned by its customers. Therefore, the activities of printing of duplex board belonging to its customers would be treated as supply of services. 4.3 Further, clause (68) of section 2 of the GST Act defines the term 'job work' as under: '....

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....to- *** (b) printing of all goods falling under Chapter 48 or 49, which attract State tax @ 6 per cent. 6       (ib) ***         (ic) ***         (id) Services by way of job work other than (i), (ia), (ib) and (ic) above; 6       (ii) Services by way of any treatment or process on goods belonging to another person, in relation to - (a) printing of newspapers; (b) printing of books (including Braille books), journals and periodicals. (c) printing of all goods falling under Chapter 48 or 49, which attract State tax @ 2.5 per cent. or Nil. 2.5       (iia....

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....der point no. (i) to (iv) would attract tax @ 18% [CGST @ 9% + WBGST @ 9%]. 4.6 We further find that Chapter 48 of the Customs Tariff Act specifies 'Paper and paperboard; articles of paper pulp of paper or of paperboard'. Duplex board, being a form of paper board, falls under this Chapter and attracts tax @ 12% [CGST @ 6% + WBGST @ 6%] vide entry no. 112 of Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017 [corresponding West Bengal Tax Notification No.1125 F.T. dated 28.06.2017]. 4.7 On the basis of above, we hold that the activities undertaken by the applicant for printing on duplex board belonging to its customer including cutting, punching and lamination, as and when required by the customer, shall be treated as service....