Printing Treated as Service When Content Not Owned: AAR Imposes 18% GST

In re Maharashtra State Burau of Textbook production & Curriculum Research (GST AAR Maharashtra)

The Authority for Advance Ruling (AAR), Maharashtra examined multiple questions regarding the classification and taxability of supplies made by the Maharashtra State Bureau of Textbook Production & Curriculum Research under the GST framework. The Bureau, an autonomous body engaged in preparation, printing, and distribution of textbooks and educational materials, sought clarity on whether various transactions involving printing and supply of books constituted supply of goods or services and the applicable GST rates.

The central issue revolved around determining the nature of supply based on ownership of content and application of GST provisions, including Circular No. 11/11/2017-GST and relevant notifications. The AAR noted that under GST law, classification depends on the “principal supply” in a composite transaction. Where the intellectual property (content) is owned by the printer/publisher and books are printed using their own materials, the transaction constitutes supply of goods classifiable under HSN 4901, which is exempt from GST. Conversely, where content is supplied by the recipient and the printer merely undertakes printing using its own inputs, the transaction constitutes supply of services classifiable under SAC 9989 and taxable at 18%.

Applying this principle, the AAR ruled that printing of Tamil and Bengali textbooks, where content was supplied by government authorities and the Bureau did not own copyright, amounted to supply of printing services taxable at 18%. Similarly, printing of online admission booklets on behalf of the Directorate of Education was also classified as supply of services under SAC 9989 and subject to 18% GST.