Page 143 - GSTL_30th April 2020_Vol 35_Part 5

2020 ] IN RE : DEPARTMENT OF PRINTING, STATIONERY AND PUBLICATIONS 629
Para 5 of the circular specifies that in the case of supply of printed en-
velopes, letter cards, printed boxes, tissues, napkins, wall paper etc., falling
under Chapter 48 or 49, printed with design, logo etc., supplied by the re-
cipient of goods but made using physical inputs including paper belonging
to the printer, predominant supply is that of goods and the supply of print-
ing of the content [supplied by the recipient of supply] is ancillary to the
principal supply and therefore such supplies would constitute supply of
goods falling under respective headings of Chapter 48 or 49 of the Customs
Tariff.
In the instant case, the applicant is engaged in printing & sup-
ply of Answer sheets/visiting cards/letter heads/forms/covers/file
wrappers/invitation cards/scribbling pads/rubber stamps to vari-
ous Government Departments, where the content is provided by any
of the department of Government of Karnataka and hence supply of
the said items amounts to supply of goods, in terms of para 5 of the
aforesaid circular.
The applicant claims exemption, in relation to supply of items
of this category, under Sl. No. 150 of Notification 2/2017-Central Tax
(Rate), dated 28-6-2017, which exempts supply of goods by a Gov-
ernment Entity to the State Government i.e. Government of Karna-
taka. In the instant case the applicant is not a Government Entity and
hence the said entry is not relevant to the instant issue.
Thus the impugned activity of printing and supply of Answer
sheets/visiting cards/letter heads/forms/covers/file wrappers/
invitation cards/scribbling pads/rubber stamps to other Depart-
ments of same Government of Karnataka who have not obtained
separate registration under the GST Act does not qualify as supply in
terms of Section 7(1)(a) of the CGST Act, 2017, as explained in para
10(a) supra. However, if the said supply is done to the other De-
partments of Government of Karnataka who have obtained separate
registration under the GST Act, said transaction qualify as supply in
terms of Section 7(1)(a) of the CGST Act, 2017 and liable to tax under
GST.
(c) Supply of Service to Autonomous bodies :
This category covers questions bearing Numbers 8 & 20, which
deals with printing & supply of Annual Reports/Receipt Books re-
spectively, to autonomous bodies i.e. BRTS Company, Hubli-
Dharwad Karnataka Electricity Regulatory Commission,
Chamundeshwari Electricity Supply Company, Power Company of
Karnataka Limited, BESCOM/HESCOM/MESCOM/KPTCL,
Udupi/Bellary Nagarabhivrudi Pradhikara, Higher Education
Council; content is provided by autonomous bodies; physical inputs
including paper belong to the applicant.
The printing of books/annual reports and like, where content is sup-
plied by the persons who owns the usage rights to the intangible inputs,
while the physical inputs including paper used for printing belong to the
printer would constitute a composite supply, where the principal supply is

GST LAW TIMES  30th April 2020  143