TaxTMI 
TaxTMI 
2026 (8) TMI 623
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....o as "the Principal") to the applicant under delivery challan, for the purpose of offset printing, in accordance with precise specifications, designs and instructions provided by the Principal; that upon completion of offset printing, the processed Kraft paper sheets and Duplex paper are returned to the Principal for further processing, that at no point in time does the ownership in goods pass to the applicant and the title, risk and ownership of goods always remain with the Principal. 3. The applicant has further submitted that they do not manufacture corrugated boxes or any finished packaging product; that the applicant's activity is confined only to printing which does not alter the essential character of Kraft Paper or Duplex Paper; that the services provided by the applicant are appropriately classifiable under Heading 9988 - "Manufacturing services on physical inputs (goods) owned by others," i.e. Job Work Services; that charges such as cutting, paper sheet loading, bundle unloading, plate charges apart from printing services are shown separately on Sale Invoice for rate transparency only and are ancillary and incidental to the principal supply of printing services. Th....
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.... owner of goods, is free to use, divert or dispose of the printed material in any manner without the applicant's consent. • There is no certainty that the printed paper supplied by the applicant is necessarily or exclusively used for the manufacture of corrugated boxes. • Despite the above, the Principal insists that the GST @ 5% should be charged on job work services, on the basis of GST rate applicable to the final product which mandates rate determination based on the goods on which job work is actually performed. • The GST rate applicable to job work services must be determined with reference to the goods on which the job work is actually performed and not with reference to the ultimate finished product manufactured by the Principal. • In the present case, job work is performed on Kraft Paper and Duplex Paper, both falling under Chapter 48, taxable at 18%. • The applicant's activity is printing on paper as such, which continues to remain paper even after printing. The applicant's role is strictly limited to job work, with no nexus to the manufacture of corrugated boxes, either contractually or function....
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.... services on physical inputs (goods) owned by others," i.e. Job Work Services & charges such as cutting, paper sheet loading, bundle unloading, plate charges apart from printing services are shown separately on Sale Invoice for rate transparency only and are ancillary and incidental to the principal supply of printing services. 10. Ongoing through the application filed by the applicant as well as the various documents submitted, we find that the activities carried out by the applicant is job work services on the Kraft papers and Duplex papers received from the Principal Manufacturer. The various activities include cutting of paper reel into required sheet size > sorting and stacking of cut sheets > plate making/ plate mounting > offset printing > drying/curing of printed sheets, varnish/lamination process (if required) > quality check and colour matching > bundling/packing of printed sheets > return of printed material to the principal manufacturer. Further, as submitted by the applicant, the job work service done on the Kraft papers and Duplex papers does not alter the nature of the said goods as the same are returned to the principal manufacturer after the completion of job wo....
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....urning back the bundled/packed printed sheets to the principal manufacturer indicates that they are all interconnected with each other and can be stated to be "naturally bundled" and supplied in conjunction with each other in the ordinary course of business. We also find that activity of offset printing is the main supply and all the other supplies carried out pre-offset printing and post-offset printing, can be considered as supporting the main activity/supply of offset printing i.e. the said activities/supplies can be considered as ancillary to the supply of offset printing. We, therefore, find that the supply of services provided by the applicant will indisputably fall under the definition of "composite supply" where offset printing is the "principal supply". Further since the type of supply of the job work services provided by the applicant has already been identified as a "composite supply", the need to refer to the definition of "mixed supply" does not arise. 11. Now, having decided the type of supply of services provided by the applicant, it becomes imperative to find out the rate of GST applicable on the "composite supply" of job work service. Section 8 of the CGST Act, ....
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...." and the GST rate in the corresponding column "4" is shown as 2.5%. A plain reading of the said entry indicates that the rate of CGST would be 2.5%, if and only if, the rate of CGST of the goods on which the aforementioned job work service has been carried out is 2.5% or NIL. This also implies that this entry is applicable, if an only if, the goods (falling under Chapter 48 & 49 in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) on which the aforementioned job work service is carried out, is chargeable to CGST at the rate of 2.5% or NIL. This also indicates that if the rate of CGST on the goods (falling under Chapter 48 & 49 in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) on which the aforesaid job work service has been carried out is other than 2.5%, entry No. 26(ii)(f) is not applicable. 12.1 In the issue in hand, we find that the job work service / composite supply of "offset printing" has been carried out on Kraft paper (classifiable under CTH 4810 of the Customs Tariff Act) and Duplex paper (classifiable under CTH 4804 of the Customs Tariff Act) owned by the principal manufacturers and the said Kraft paper and Duplex paper, after the comp....