Page 120 - GSTL_26th March 2020_Vol 34_Part 4
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630 GST LAW TIMES [ Vol. 34
ner/billboard etc., and thus the nature of the material changes. Further the appli-
cant does not own or retain the usage rights of intangible inputs. In view of the
foregoing the activity of printing of the content, supplied by the recipient, on the
PVC material becomes principal supply and such supply constitute supply of
service falling under SAC 9989.
11.13 The Applicant referred to several judgments of the Apex Court
and the Tribunal, which are all related to the classification of the goods being
supplied (Trade Advertising Material) as to whether they are to be classified un-
der Chapter 39 or 49 of the Tariff Act. This authority does not dispute the classi-
fication of the said goods under Chapter 49. However, in the instant case such
supplies are ancillary to the principal supply of Printing Service.
12. In view of the foregoing, we pass the following :
RULING
(1) The transaction of printing of content provided by the customer, on
Poly Vinyl Chloride (PVC) banners and supply of such printed
trade advertisement material is supply of service.
(2) The classification of aforesaid supply of service is 9989 of the
scheme of classification of services.
(3) The applicable rate of GST on the supply of aforesaid service is 18%
up to 30-10-2017 & 12% effective from 31-10-2017, as per Entry No.
27 of the Notification No. 11/2017-Central Tax (Rate), dated 28-6-
2017, as amended.
_______
2020 (34) G.S.T.L. 630 (A.A.R. - GST - Kar.)
BEFORE THE AUTHORITY FOR ADVANCE RULING UNDER GST,
KARNATAKA
Dr. Ravi Prasad M.P., Member (State Tax) and Shri Mashhood ur Rehman
Farooqui, Member (Central Tax)
IN RE : M.V. INFRA SERVICES PVT. LTD.
Advance Ruling No. KAR ADRG 04/2020, dated 17-2-2020
Skill development training - Services provided under sub-contract to
main contractor, who in turn provides to Maharashtra State Skill Development
Society (MSSDS), in respect of training of building and other construction
workers (skill development training) - MSSDS which is neither National Skill
Development Corporation (NSDC) nor Sector Skill Council (SSC) - No docu-
mentary evidence produced so as to arrive at whether the main contractor qual-
ifies to be training partner, approved by either NSDC or SSC - Training pro-
viders not entitled for exemption under Serial No. 69 of Notification No.
12/2017-C.T. (Rate) - Main contractor would not be entitled for exemption un-
der this entry for the said work - Main contractor, if they get work, would be
providing service, of training for Recognition of Prior Learning (RPL) to con-
struction workers, to Government of Maharashtra, for which total expenditure
to be borne by State Government - Main contractor would be eligible for ex-
GST LAW TIMES 26th March 2020 216

