Circular didn’t clarify taxability of “printed access cards” or “leaflets”.
The appellate authority for Advance Ruling (Karnataka) in case of Pattabi Enterprises observed undoubtedly the contents and the creatives for the access card have been supplied by the recipient to the appellant and there is no dispute that the appellant has used his own paper and inks and machinery to carry out the activity. However, what has been lost sight of is the fact that the activity of printing brings into existence a specific new product known in the trade and common parlance as the access card.
Therefore, the authority was on a conclusion that the printing service is not the principal supply in this case but the supply of access card (i.e. supply of goods) which is product emerging out of the printing activity.
