Page 157 - GSTL_21st May 2020_Vol 36_Part 3

2020 ] IN RE : IDEAL INDUSTRIAL SYNERGY SOLUTIONS PVT. LTD. 403
India and is desirous to know the applicability of tax on the transac-
tions.
1 3. Sri Shantiny Mathan, Accounts Executive of the above concern ap-
peared made the following submissions :
(a) That they are involved in the printing and supply of goods where
the content is provided by the religious heads and they are printing
the books and selling the same to the Madarasas. The books are not
sold to the content providers but are sold to the religious schools as
per the orders received from such schools.
(b) The billing is also done to the Madarasas and the books are also
supplied to the Madarasas. The Madarasas are not involved in the
supply of content and this is received from the religious heads.
4. Findings & Discussion :
4.1 The submissions of the applicant is verified and found that the sup-
ply is made by the applicant to the Madarasas for a consideration and the con-
tract is for the supply of books for consideration. This being in the course of
business would amount to a supply of books as per sub-section (1) of Section 7 of
the Central Goods and Services Tax Act, 2017. There is no direct link between the
recipient of books and the supplier of the content and the final product is sup-
plied to the recipient of books and the content provider has no role to play in the
selection of the recipient or the sale. Hence it is sale simpliciter of books.
4.2 Regarding the HSN Code and the rate of tax applicable on such
supply of books, it is seen that the printed books are covered under the HSN
Code 4901 10 10 and are covered under Entry No. 119 of Notification No. 2/2017-
Central Tax (Rate), dated 28-6-2017 and hence are exempt from tax under the
CGST Act, 2017. Further they are covered under Entry No. 119 of Notification
(02/2017) No. FD 48 CSL 2017, dated 29-6-2017 and hence exempted from the
Karnataka Goods and Services Tax Act, 2017. The inter-State supply of printed
books are exempt under the IGST Act, 2017 as they are covered under Entry No.
119 of Notification No. 2/2017-Integrated Tax (Rate), dated 28-6-2017.
5. In view of the foregoing, we rule as follows.
RULING
(1) The supply of books by the applicant to the religious schools are
supply of printed books which is covered under HSN Code 4901
and is exempt from tax as they are covered under following entries
(a) Under the CGST Act, Entry No. 119 of Notification No.
2/2017- Central Tax (Rate), dated 28-6-2017.
(b) Under the Karnataka Goods and Services Tax Act, Entry No.
119 of Notification (02/2017) No. FD 48 CSL 2017, dated 29-6-
2017.
(c) Under the IGST Act, Entry No. 119 of Notification No.
2/2017-Integrated Tax (Rate), dated 28-6-2017.

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1 Paragraph number as per official text.
GST LAW TIMES  21st May 2020  157