Classification of supply — In the instant case, applicant sought Advance Ruling on the following issues—
1. Whether supply of service of:
(i) Printing of Pre-examination items like question papers, OMR sheets (Optical Mark Reading), answer booklets;
(ii) Printing of Post-examination items like marks card, grade card, certificates to the educational boards of up to higher secondary; and
(iii) Scanning and processing of results of examinations; be treated as exempted supply of service by virtue of Entry No. 66 of the Notification No.12/2017-Central Tax (Rate), dated 28th June, 2017
2. What would be the classification and the applicable GST rate, for the supply of Printing of cheque book?
3. What would be the classification and the applicable GST rate, for the printing and supply of Aadhaar Cards on paper?
4. What would be the classification and the applicable GST rate, for the printing and supply of Polyvinyl chloride (PVC) Cards?
Held that—
1. the services provided to ‘educational institutions’ for conducting of examinations are eligible for exemption under entry No.66 of Notification No. 12/2017 - Central Tax (Rate), dated 28th June, 2017.
2. In respect of supply of cheque books where the printing paper and inks are being borne by the applicants, the impugned goods merit classification under Tariff heading 4907 as goods and they are an exempted supply in terms of Serial No 118 to the Notification No.02/2017-Central Tax (Rate) dated 28.06.2017. Hence, cheques or cheque books would not attract any GST and are an exempted supply in terms of the Notification.
3. Despatching of aadhaar card will not be complete unless it is printed, laminated and franked by the applicant. Accordingly, it appears that, the services rendered by the applicant merits as supply of service and accordingly falls under serial no.27 of Notification No.11/2017-Central Tax (Rate) dated 28.06.2017 as amended and the rate of tax applicable is 12% ( 6% CGST + 6% SGST).
4. in the instant case since the PVC cards are belonging to the applicant, predominant supply is that of goods and the supply of printing of the content supplied by the recipient of supply is ancillary to the principal supply of goods and therefore such supply would be classified as supply of goods falling under chapter 3920 of the Customs Tariff as made applicable to GST Tariff, hence it attracts 18% GST.Kl Hi-Tech Secure Print Ltd. [2018] 2 TAXLOK.COM 332 (AAR-Telangana)