The Andhra Pradesh Authority for Advance Ruling (AAR) has recently, in an application filed before it, ruled that the printing of mark cards, grade cards and certificates is exempted from GST.
The aforesaid ruling was made by the Authority of Advance Ruling when an application was filed before it by M/s. Universal Print Systems, the applicant, who is engaged in the business of printing including high-end security printing products from the year 2011.
The Applicant being engaged in the printing of different types of certificates with security features, so that the genuineness of these documents can be prevented from unauthorized misuse/duplication, the aforesaid activity by the applicant also involved approved printing as per the design/pattern/data, as was provided by the customer under their supervision.
The primary question involved in the application filed by the applicant being as to whether the printing of Post examination items like marks cards, grade cards and certificates to educational boards (up to higher secondary), after the scanning of OMR sheets and the processing of data in relation to the conduct of an examination, be treated as exempted supply of service, by virtue of serial Number 66 of Notification No.12/2017-CGST[Rate] dated 28-6-2017 as amended, it was submitted by the applicant that before the onset of Goods and services Tax, the activity of the Applicant was treated as manufacture by classifying the products under chapter 49/48 of the First schedule to the central Excise Tariff Act, 1985. And simultaneously, that the clearance was treated as sale within the meaning of AP VAT Act, 2005.
With the applicant further adding to his submission that with the onset of Goods and services Tax in 2017, however, a different connotation has been accorded by treating the said activity as supply of service, instead of supply of goods in as much as the Applicant does not own the goods at any stage, in the view of the security features or the nature of the goods which cannot be sold to any other person due to fiduciary value, the services rendered in printing industry, particularly in cases where the design/data/pattern is provided by the customer, are recognized to be a service, the Andhra Pradesh Authority for Advance Ruling, consisting of the members Sri. D. Ramesh, the Commissioner of State Tax and Sri. RV Pradhamesh Bhanu, the Joint Commissioner of Central Tax held that the printing of mark cards, grade cards and certificates be exempted from GST.
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