M/S TEMPLE PACKAGING PVT LTD

The Applicant is engaged in manufacture of printed leaflet at their Daman factory out of their own raw material namely paper/ink with the contents supplied by the purchaser of leaflet to whom leaflets were sold by the Applicant on principal to principal basis.

The Applicant sought Advance Ruling on "Whether the printed leaflet supplied falls under the category of supply of goods under CHS No. 4901 or supply of service under SAC No. 9989"?

The product pamphlet in itself is nothing but a media to convey the message and the message or script what is to be printed , is supplied by the buyer of the product. Therefore primary nature of the product (leaflets) is to convey the message which is a form of Service and merits classification under SAC 9989.

Further Circular No.11/11/2017 dtd. 20.10.2017 has clarified that in the case of printing of books, pamphlets, brochures, annual reports, and the like, where only content is supplied by the publisher or the person who owns the usage rights to the intangible inputs while the physical inputs including paper used for printing belong to the printer, supply of printing [of the content supplied by the recipient of supply] is the principal supply and therefore such supplies would constitute supply of service falling under heading 9989 of the scheme of classification of services. Accordingly pamphlets, brochures annual reports etc are covered under the services and the applicant is engaged in printing of pamphlets etc. hence, the correct classification of the product of the applicant is 9989.

Crux: Printing of Pamphlet/leaflet falls under the category of Supply of service falling under SAC No. 9989.