The Applicant is engaged in the printing industry and is an manufacturer of cartons, corrugated boxes, paper folders, sleeves, other packaging containers, labels, tags, pamphlets, booklets, brochures, leaflets and similar printed matter on order. Content to be printed is supplied by the customer and all the raw materials required for printing belong to the applicant. The content is printed and supplied.
The applicant is supplying “Access Card” to a customer,M/S. Trilok Security Systems India Pvt. Ltd, on their specific requirement and all the contents to be printed on the Access Card are provided by the said customer.
The applicant submitted that “Access Card” was only a printed matter issued to pilgrims free of cost by temple i.e. Tirumala Tirupati Devasthanams, Shri Shiv Khori Shrine Board and other temples, which contain information regarding distance to the temple, precautions to be taken by pilgrims who are old, sick physically weak, first aid centers and certain restrictions on the movement of pilgrims. It is used for security reasons and it stipulates and restricts the staying time of pilgrims inside the temple area. “Access Card” is issued in public interest with social messages and it is non-commercial in nature i.e., neither promotes trade nor commerce.
The applicant further submitted that on implementation of Goods and Service Tax Act, 2017, with effect from 01.07.2017, the goods are classified under HSN Code and divided into different schedules for the purpose of levy of GST. Accordingly, the description of goods falling under HSN code 4901 10 20 is similar to the description provided.
The Applicant had sought advance ruling on classification of goods and services is as under the Access Card being printed and supplied by applicant is classifiable under HSN code 4901 10 20 with description brochures, leaflets and similar printed matter whether or not in single sheet and rate of tax at “CGST 2.5% & SGST 2.5%” and IGST 5% and applicant is seeking advance ruling. The authority observed that the involvement of rights to stay in the temple precincts attached to the card and other involvement of privileges can only be issued by the recipient of supply of “Access Cards”, the same is to be treated as Composite supply with the supply of services being the principal supply.
It was further observed that Section 8(1)(a) of the Central GST Act mandates that in case of a composite supply comprising of two or more supplies, where one of these supplies is the principal supply, such composite supply shall be treated as a supply of such principal supply.
The Authority of Advance Ruling ( AAR ), Karnataka has ruled that,” The supply of “access cards” and similar material printed by the applicant with the contents supplied by the recipient of supply are classifiable under SAC 9989 and liable to tax under CGST @9%, KGST @9% and at IGST@ 18% under the IGST Act”.