Page 149 - GSTL_13th August 2020_Vol 39_Part 2

2020 ] IN RE : MACRO MEDIA DIGITAL IMAGING PVT. LTD. 235
same provision under the APGST Act. Further, henceforth, for the purposes of
this Advance Ruling, a reference to such a similar provision under the CGST or
APGST Act would be mentioned as being under the GST Act.
3. Brief facts of the case :
3.1 M/s. Macro Media Digital Imaging Private Limited, Plot 44, Appar-
el Export Park, Auto Nagar, Visakhapatnam-530012, (hereinafter referred to as
the Applicant) is engaged in the business of printing of trade advertising materi-
al, for which required raw materials such as poly vinyl, flex, paper, cloth printing
inks etc. are being procured by themselves. The activity of printing is based on
specification provided by the clients in terms of design, size, material specifica-
tion etc. The applicant states that their activity of printing on such poly vinyl ma-
terial with trade monograms of the customers constitutes ‘manufacture’ in terms
of Central Goods and Services Tax Act, 2017 and such manufactured products
are supplied by the applicant to the customers.
3.2 The applicant besides having its main office at Visakhapatnam, op-
erates from the various regional offices located at Chennai, Noida, Vishakhapat-
nam, Vijayawada, Mumbai, Bangalore, Kochi, Kolkata, and engaged in printing
of following :- Billboards; Building Wraps; Fleet Graphics; Window Graphics;
Trade Show Graphics; Office Branding; In-store Branding; Banners; Free Stand-
ing Display Units; and Signage Graphics. The above referred printed products
are hereinafter referred to as ‘trade advertisements’.
3.3 The printing of trade advertisements is carried out by the Applicant
on Poly Vinyl Chloride (hereinafter referred to as ‘PVC’) material. Various types
of PVC material on which printing is carried out by the Applicant vis-a-vis their
Harmonized Commodity Description of Coding System Nomenclature (hereinaf-
ter referred to as “HSN”) classification are listed as under :-

Sl. No. PVC Material Name HSN Classification
1. Vinyl (self-adhesive) 3919 90 50/3919 90 90
2. Back Lit Flex 3921 90 26
3. Block out Flex 3921 90 26
4. Foam Board 3920 61 90

Modus operandi of the applicant
3.4 The customers desirous of getting images/written text/trade mon-
ograms printed from the Applicant place a purchase order on the Applicant. The
said purchase order spells out the type and specifications of the material on
which the trade advertisement (provided by the customer) is to be printed.
3.5 The scope of work of the Applicant under any such purchase order
placed by the customer is as under :-
(a) To procure the PVC material (blank) from an independent supplier
in terms of the purchase order placed by the customer.
(b) The data of image/text/trade monograms to be printed on the PVC
material is received by the Applicant from the customer, via mode
of pen drive/CD/cartridge. The image/text/trade monogram in
the said CD/Pen Drive/cartridge is later loaded into the computer
controlled digital image printer, which prints the images on the
PVC material. In cases where desired size of the trade advertise-
ment is more than the size of PVC material that can be accommo-
GST LAW TIMES  13th August 2020  149