Case Law Details
In re Macro Media Digital Imaging Pvt Ltd. (GST AAR West Bangal)
The Applicant prints billboards, building wraps, fleet graphics, window graphics, trade show graphics, office branding, in-store branding, banners, signage graphics etc., commonly known as trade advertising material, classified under heading 4911 of the Tariff Act. The recipient provides on a digital media the content in the form of image/text/trade monogram and retains usage right on such intangible inputs. The Applicant loads the content in a digital image printer, prints the image on the PVC material, and supplies the printed material. The goods so supplied have no utility other than displaying the printed content. Service of printing, therefore, is the predominant element of the composite supplies the Applicant is making.
Services by way of printing of the goods falling under Chapter 48 and 49 are classifiable under SAC 9989 and taxable under SI No. 27(i) of Notification No. 11/2017 – CT (Rate) dated 28/06/2017 (corresponding State Notification No. 1135 — FT dated 28/06/2017). The Applicant, being a printer of trade advertising material classifiable under heading 4911 of the Tariff Act, is making a composite supply, where the service of printing classifiable as above, is the principal supply. The goods supplied, having no use other than displaying the printed matter, is ancillary to the principal supply of printing.
The Applicant has referred to several judgements of the apex court and the tribunal. They are all related to the question of classifying the goods being supplied, whether they are to be classified under Chapter 39 or 49 of the Tariff Act. This Authority does not dispute that the goods supplied are classifiable under Chapter 49. But such supplies are ancillary to the principal supply of printing service.
The Applicant is making a composite supply, where the service of printing is the principal supply. The goods supplied, having no use other than displaying the printed matter, is ancillary to the principal supply of printing.
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