Page 116 - GSTL_26th March 2020_Vol 34_Part 4

626 GST LAW TIMES [ Vol. 34
2020 (34) G.S.T.L. 626 (A.A.R. - GST - Kar.)

BEFORE THE AUTHORITY FOR ADVANCE RULING UNDER GST,
KARNATAKA
Dr. Ravi Prasad M.P., Member (State Tax) and Shri Mashood Ur Rehman
Farooqui, Member (Central Tax)
IN RE : MACRO MEDIA DIGITAL IMAGING PVT. LTD.
Advance Ruling No. KAR ADRG/06/2020, dated 17-2-2020
Printing of advertising material - Supply of goods or services -
Assessee on orders from its customers printing of content of advertisement
provided by customers on material specified and supplied by it to customer -
Poly Vinyl Chloride (PVC) material classified under Chapter 39 of Customs
Tariff Act, 1975 prior to printing and after printing it would become Trade Ad-
vertising Material fell under Chapter 49 ibid - Activity of printing making
PVC material into trade advertising material, i.e., banner/billboard, etc. - Ac-
tivity bringing about material changes in nature of PVC - Assessee not owning
or retaining usage rights of intangible inputs - Activity of printing of content
supplied by recipient, on PVC material becomes principal supply - Supply of
material ancillary to principal supply of printing service - Printing of content
provided by customer on PVC banners and supply of such printed trade adver-
tisement material amounted to supply of service as clarified by C.B.E. & C.
Circular No. 11/11/2017-GST, dated 20-10-2017 - Supply classifiable under SAC
9989 and taxable at 18% up to 30-10-2017 and 12% effective from 31-10-2017, as
per Serial No. 27 of Notification No. 11/2017-C.T. (Rate) as amended - Section 9
of Central Goods and Services Tax Act, 2017. [paras 11.6, 11.7, 11.8, 11.9, 11.10,
11.11, 11.12, 11.13, 12]
Ruling in favour of department
CASES CITED
Macro Media Digital Imaging Pvt. Ltd. — 2018 (14) G.S.T.L. 97 (A.A.R. - GST) — Referred .... [Para 11.4]
Macro Media Digital Imaging Pvt. Ltd. — 2019 (29) G.S.T.L. 33 (A.A.R. - GST) — Referred .... [Para 11.4]
DEPARTMENTAL CLARIFICATION CITED
C.B.E. & C. Circular No. 11/11/2017-GST, dated 20-10-2017 ......... [Paras 7, 11.6, 11.7, 11.9, 11.10, 11.11]
REPRESENTED BY : Shri Syed M. Peeran, Advocate, for the Assessee.
[Order]. - M/s. Macro Media Digital Imaging Pvt. Ltd. (called as the
‘Applicant’ hereinafter), # 32/1, Visweswaraiah Indl. Estate, KIADB Road, Ma-
hadevapura, Bengaluru Urban-560048, Karnataka, having GSTIN Number
29AABCM9451F1ZA, have filed an application for Advance Ruling under Sec-
tion 97 of CGST Act, 2017 & KGST Act, 2017 read with Rule 104 of CGST Rules,
2017 & KGST Rules 2017, in Form GST ARA-01 discharging the fee of Rs. 5,000/-
each under the CGST Act and the KGST Act.
2. The applicant is engaged in the business of printing of trade adver-
tising material (Billboards, Building Wraps, Fleet Graphics, Window Graphics,
Trade Show Graphics, Office Branding, In-store Branding, Banners, Free Stand-
ing Display Units and Signage Graphics), for which required raw materials such
as poly vinyl, flex, paper, cloth printing inks etc., are procured by themselves.
The activity of printing is based on specifications provided by the clients in terms
of design, size, material etc.

GST LAW TIMES  26th March 2020  212