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Circular No. 11/11/2017-GST

F. No. 354/263/2017-TRU
Government of India
Ministry of Finance
Department of Revenue
Tax research Unit
****
North Block, New Delhi
20
th
October 2017
To,
The Principal Chief Commissioners/Chief Commissioners/ Principal Commissioners/
Commissioner of Central Tax (All) /
The Principal Director Generals/ Director Generals (All)

Madam/Sir,

Subject: Clarification on taxability of printing contracts

Requests have been received to clarify whether supply of books, pamphlets, brochures,
envelopes, annual reports, leaflets, cartons, boxes etc., printed with design, logo, name, address
or other contents supplied by the recipient of such supplies, would constitute supply of goods
falling under Chapter 48 or 49 of the First Schedule to the Customs Tariff Act, 1975 (51of 1975)
or supply of services falling under heading 9989 of the scheme of classification of services
annexed to notification No. 11/2017-CT(R).

2. In the above context, it is clarified that supply of books, pamphlets, brochures, envelopes,
annual reports, leaflets, cartons, boxes etc. printed with logo, design, name, address or other
contents supplied by the recipient of such printed goods, are composite supplies and the question,
whether such supplies constitute supply of goods or services would be determined on the basis of
what constitutes the principal supply.

3. Principal supply has been defined in Section 2(90) of the Central Goods and Services Tax
Act as supply of goods or services which constitutes the predominant element of a composite
supply and to which any other supply forming part of that composite supply is ancillary.

4. 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.

Circular No. 11/11/2017-GST

5. In case of supply of printed envelopes, letter cards, printed boxes, tissues, napkins, wall
paper etc. falling under Chapter 48 or 49, printed with design, logo etc. supplied by the recipient
of goods but made using physical inputs including paper belonging to the printer, 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 supplies would constitute
supply of goods falling under respective headings of Chapter 48 or 49 of the Customs Tariff.

4. Difficulty if any, in the implementation of the circular should be brought to the notice of
the Board. Hindi version would follow.

Yours Faithfully,

Rachna
Technical Officer (TRU)
Email: rachna.irs@gov.in