Classification of Supply — This appeal has been filed against advance ruling pronounced by the West Bengal Authority for Advance Ruling The WBAAR in its Ruling No.15/ WBAAR/ 2019-20 dated 19.08.2019, observed inter alia, that the transaction involves a composite supply - a transaction involving both supply of goods in the form of printed PVC material and of the service of printing the content provided by the recipient, which are inseparable in the execution of the contract. According to the WBAAR, the printed trade advertisement material has no utility other than displaying the printed content. It held that the service of printing is the predominant element of the composite supplies the Appellant is making. Thus, the WBAAR held that the goods classifiable under Chapter 39 and 49 of Customs Tariff Act, 1975 (hereinafter referred to as the “Tariff Act”) are supplied by the appellant but the supply of the said items are ancillary to the principal supply of printing service.

Held that -The Appellant argued that the product description in their invoice is mentioned as “Printing and Supply of Trade Advertisement Material – HSN # 4911”, because what they supply are primarily goods. However, we find that in the purchase order no. 5000060092 dated 12.04.2019, ITC Limited has mentioned the order description as service - “Digital Printing - Outdoor”. Also in purchase order issued to the Appellant under no. 018/EMPL/18-19 dated 24.05.2018 issued by Eden Media Pvt. Ltd, the particular of charges has been mentioned as “Printing charges for 1 no. of Blackback flex”. Thus, it is clear beyond doubt that what the Appellant supplies is nothing but service. Hence, we find no basis in the argument of the Appellant that it supplies goods only. — Macro Media Digital Imaging Pvt. Ltd., In Re… [2019] 19 TAXLOK.COM 096 (AAAR-WB)