Rate of Tax — Applicant seeking an advance ruling on following issues :

(a) Applicability of GST rate on selling of space/ time for advertisement in print media in case of advertising companies;

(b) Applicability of GST rate if advertising company/ agency sells unit of Space in print media to client and designing/ composing is being done by advertising company/agency without charging separately in the bill for designing, etc., to client;

(c) Selling of space/ time for advertisement in print media by advertising companies is a pure service or otherwise. If yes, whether said pure service is exempted from payment of GST vide Notification No. 12/2017-Central Tax (Rate), dated 28th June, 2017 when advertising agency is raising bill to Local Authority or otherwise; and

(d) If exemption is available to local authority then said exemption is also available to advertising companies or not.

(i) Selling of space for advertisement in print media by advertising company/ agency shall attract GST @ 5% [2.5% CGST + 2.5% SGST] in case of advertising companies/ agencies in all cases. However Volume incentives/ value incentives are part of commission and cannot be treated as sale of space in print media and therefore incentive will be charged @ 18%.

(ii) Composite supply comprises of selling of space in print media and designing/composing of the advertisement, shall attract GST @ 5% [2.5% CGST + 2.5% SGST] inasmuch as "selling of space in print media" is a principal supply which attract GST @ 5% [2.5% CGST + 2.5% SGST] as on date. Advertisement company/agency sells unit of space in print media to client and designing/composing is being done by advertising company /agency without charging separately in the bill for designing, etc., to client. Such case is a case of composite supply and in such case "selling of space in print media" is a principal supply. Hence it will attract GST @ 5% [2.5% CGST + 2.5% SGST] as on date.

(iii) Supply of service viz. "Sale of Space for Advertisement in Print Media" is not a "Pure Service" and the exemption to said services are not admissible in terms of Notification No. 12/2017-CentraI Tax (Rate), dated 28-6-2017 (as amended from time to time).

(iv) The exemption from GST is also not available to the applicant in terms of Notification No. 12/2017-CentraI Tax (Rate), dated 28-6-2017 (as amended from time to time). — Harmilap Media (P) Ltd., In Re.. [2019] 13 TAXLOK.COM 100 (AAR-Uttarakhand)