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The trade advertisements made by the Appellant are classifiable under sub-heading 4911 10 under the category of trade advertising material, commercial catalogues and the like. They will fall under the description goods under Heading 4911 and taxable @12%

Classification of supply- the issue before us is to decide whether the activity of printing trade advertisement material by the Appellant using the blank PVC material procured by them and the design and graphics provided by the customer is an activity of supply of goods or supply of service. The classification and the GST rate applicable will depend on the determination of the nature of activity. We disagree with the reasoning by the lower Authority. For the creation of any item where printing is involved, the ‘content’ will always be given by the owner/customer and it is the customer who will have the usage rights to the content. In our view, the Circular No 11/11/2017 GST dt 20-10-2017 will not be applicable to the case of this Appellant since the contract given by the customers is not a printing contract. It is a contract for the supply of trade advertising material wherein printing is involved in the making of the trade advertisement. Held that- The trade advertisements made by the Appellant are classifiable under sub-heading 4911 10 under the category of trade advertising material, commercial catalogues and the like. They will fall under the description goods under Heading 4911 given in entry Sl.No 132 of Schedule II of Notification No 01/2017 CT (R) dated 28.06.2017
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