Classification of Supply — In the instant case, applicant requesting advance ruling as regards :-

1. Whether the books which the Chhattisgarh Text Book Corporation is supplying as per instruction of School Education Department CG [Loksikshan Sanchnalay] after printing the Syllabus decided by the SCERT would tantamount to supply of goods or supply of Service and fall under HSN Code 4901 zero rated goods.

2. Whether the books which the Chhattisgarh Text Book Corporation, is supplying as per instruction of School Education Department [Loksikshan Sanchnalay] after printing the Syllabus decided by the SCERT would tantamount to supply of service and will fall under Services Accounting Code 9989 accordingly amenable to tax @ 12%?

3. Whether the books which the Chhattisgarh Text Book Corporation is supplying as per instruction of various agencies of School Education Department CG such as Rajiv Gandhi Siksha Mission/SCERT/office of District education officer etc. would tantamount to supply of goods and will fall under the zero rated goods.

4. Whether the books which the Chhattisgarh Text Book Corporation is supplying as per instruction of various agencies of School Education Department CG such as Rajiv Gandhi Siksha Mission/SCERT/office of District education officer etc. would tantamount to supply of service and will fall under Services Accounting Code 9989 accordingly amenable to tax @ 12%.

Held that—
Supply of specified printed Educational books by Chhattisgarh Text Book Corporation as per the instructions of School Education Department CG [Loksikshan Sanchnalay] or as per instruction of various agencies of School Education Department CG such as Rajiv Gandhi Siksha Mission/SCERT/office of District Education officer etc. consequent to printing of the Syllabus as decided by the SCERT, merits consideration as supply of printed books attracting zero rate, under Notification No. 2/2017-State Tax (Rate) No. F-10-43/2017CT/V/70, dated 28-6-2017, under HSN code 4901.—Ashok Chaturvedi, In Re… [2018] 7 TAXLOK.COM 086 (AAR-Chhattisgarh)