In re Ebenezer Printpack Private Limited (GST AAR Kerala)
Summary: The Kerala Authority for Advance Ruling considered the GST classification and rate applicable to printing activities undertaken by Ebenezer Printpack Private Limited under two different operational arrangements. Where both the paper and content are supplied by the customer and the applicant merely undertakes printing using its own consumables such as ink, chemicals, plates and other materials, the Authority held that ownership of both the paper and printed output remains with the customer.
The activity amounts to treatment or process undertaken on goods belonging to another person and is classifiable under SAC 9988 as “Manufacturing services on physical inputs (goods) owned by others”. The Authority examined the definition of “job work” under Section 2(68) of the CGST Act, 2017 and observed that an activity qualifies as job work only where treatment or process is undertaken on goods belonging to another registered person. Consequently, whether a particular transaction is covered as job work depends upon the recipient’s registration status. Under Entry No. 26 of Notification No. 11/2017-Central Tax (Rate), as amended by Notification No. 15/2025-Central Tax (Rate), printing services falling within the specified concessional sub-entries attract 5% GST, whereas residual entries attract 18% GST.
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