TaxTMI 
TaxTMI 
2026 (9) TMI 1569
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....ng process, namely the paper and the content to be printed which are discussed as under- a) Job Work Printing - In certain cases, the applicant undertakes printing as a job work activity wherein the paper required for printing is supplied by the customer and the content to be printed is also provided by the customer. In such circumstances, the applicant undertakes the printing process using its own consumables such as ink, chemicals, plates and other materials which are incidental to the printing process. Throughout the course of such transactions, the ownership of both the paper and the printed output remains with the customer. The printed output in such cases may include brochures, pamphlets, labels, periodicals, booklets and other similar commercial printed materials. b) Printing of Religious Books or Extracts - The applicant also undertakes printing of religious books or extracts of religious texts such as the Bible, the Quran and the Bhagavad Gita. In such cases, the content for printing may either be provided by the customer in digital or formatted form or may be sourced from the public domain. However, the paper and other raw materials and consumables requi....
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....s forwarded to the jurisdictional officer as per provisions of section 98 (1) of the CGST Act. The Jurisdictional officer reported that there are no pending or decided proceedings against the applicant under any provisions of the CGST Act 2017. 6. Personal Hearing: The applicant was granted an opportunity for a personal hearing on 05-01-2026. Shri. T.F. James, Director represented for the applicant in personal hearing. During the course of hearing, he explained the nature of activity undertaken by the applicant and reiterated the contentions submitted in the written application. 7. Discussion and Findings: 7.1 On review of the application, facts, and hearing submissions, it is observed that the questions for which ruling is sought by the applicant, relate to classification of goods or services and applicability of a notification and therefore fall under Section 97(2) (a) and (b) of the CGST Act, 2017 (hereinafter referred to as 'Act'). The application is therefore admitted for consideration on merits. 7.2 The submissions made by the applicant suggest that they are engaged in providing printing services such as brochures, leaflets, pamphlets, diaries, danglers, bookle....
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....GST. 7.6 Having discussed the nature of activity carried out by the applicant in cases where both content and paper are supplied by the customer, lets proceed to determine the classification of the activity/services as to which SAC it falls and the applicable rate of tax for such services. S1. 26 of the Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017, provides for the classification of "treatment or process undertaken by a person on goods belonging to another" both in the nature of "Job work" and otherwise. The relevant provisions of the Entry No. 26 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017, as amended by Notification No. 15/2025-Central Tax (Rate) dated 17.09.2025 is reproduced as under: SI.No. Chapter, Section, or Heading Description of Services Rate (per cent.) Condition 26 Heading 9988 (Manufacturing services on physical inputs (goods) owned by others) (ii) Services by way of job work in relation to- (a) .. ... (e) Printing of newspapers, books (including Braille books), journals and periodicals; (f) Printing of all goods falling under Chapters 48 or 49 in the First Schedule to the Customs Tariff Act, 19....
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....goods falling under Chapters 48 or 49 of the First Schedule to the Customs Tariff Act, 1975. Thus, the notification extends the concessional rate of GST @5% both to the printing of the specified publications and to the printing of other eligible goods falling under Chapters 48 or 49 satisfying the prescribed condition regarding the rate of tax applicable to such goods. However, clauses (f) and (b) do not extend the concessional rate to all goods falling under Chapters 48 or 49 rather the benefit is confined only to those goods classifiable under the said Chapters which themselves attract Central Tax at the rate of 2.5% or Nil. In the present case, the applicant has stated that the printing activity undertaken by it relates to products such as brochures, pamphlets, booklets, labels, posters and religious books, which seems classifiable under Chapters 48 or 49 of the First Schedule to the Customs Tariff Act, 1975. Though the application does not specify whether the goods on which the printing activity is undertaken belong to a registered person or otherwise, in either case, irrespective of the registered status of the customers, the printing of publications covered ....
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....dled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply. Further, Section 2(90) of the CGST Act, 2017 defines "principal supply" to mean the supply of goods or services which constitutes the predominant element of a composite supply and to which any other supply forming part of that composite supply is ancillary. From the facts of the case it seems that components of supply, i.e., paper & consumables and activity of printing are naturally bundled with each in ordinary of course of business for the printing trade where printing is the Principal supply. Therefore, taxability of such composite supply should be determined in terms of Section 8 of the Act, 2017. 7.11 This is further reinforced by the Circular No. 11/11/2017-GST dated 20.10.2017 which has clarified that where the content is supplied by the publisher or the person owning the usage rights to the intangible inputs and the printer uses his own physical inputs, including paper, for printing books, pamphlets, brochures, annual reports and similar publications, the principal supply is the service of printing the content, while the supply of paper and other consu....
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....ctivity of printing undertaken on paper and content supplied by the customer, using the printer's own consumables, is classifiable under SAC 9988 - Manufacturing services on physical inputs owned by others (job work)? Ruling-The activity of printing undertaken on paper and content supplied by the customer, using the printer's own consumables, is classifiable under SAC 9988. However, whether such activity would be considered as Job Work only if the customer/recipient of such services provided by the applicant is registered under GST. In other cases, it would be classified as services by way of any treatment or process on goods belonging to another person. Question 2- If classified under SAC 9988, whether such printing activity is eligible for GST at the rate of 5% in terms of Entry No. 26 of Notification No. 11/2017-Central Tax (Rate), as amended, when the printed goods fall under chapter 48 or Chapter 49? Ruling- The printing activity classifiable under Heading 9988, would be eligible for concessional rate of GST @5% only if printing services fall under sub-entries (ii) (e) & (f) and (v) (a) & (b) of Entry No. 26 of Notification No. 11/2017-Central Tax (Rate), as amended. ....