Services that Do not Include Any Supply of Goods can be Categorized as Pure Services: AAR [Read Order]

The West Bengal Authority for Advance Ruling ( AAR ) of Goods and Services Tax matters has ruled that supply of services which does not involve any supply of goods can be regarded as pure services.

The assessee contended that Jharkhand Council of Educational Research and Training, Ranchi has awarded contracts to him for printing and supply of text books under State Plan for academic session 2023- 24 on the basis of content provided by the JCERT, printing and supply of Atlas, Dictionary, Grammar and General Knowledge Book.

The assessee, Swapna Printing Works Pvt Ltd is stated to be engaged in the business of printing books and other items. Assessee contended that  the applicant will have temporary copyright over the content of the text books against consideration to be paid in the form of royalty. The applicant has also received contracts for printing and supply of Notebooks under School Kit Scheme of State Government for 2023-24 and printing and supply of Bilingual Parental Calendar from Jharkhand Education Project Council. Another contract for printing and supply of Pupils Comprehensive Report Progress Card has been awarded to the applicant by the Office of the Mission Director, Axom Sarba Siksha Abhiyan Mission, Assam.

The two member bench comprising Tanisha Dutta ( Joint Commissioner, CGST & CX ) and Joyjit Banik ( Senior Joint Commissioner, SGST ) held that “term “pure services‟ has not been defined under the GST Act. However, a bare reading of the description of services as specified in serial number 3 above denotes that supply of services which does not involve any supply of goods can be regarded as pure services. The said entry serial, therefore, specifically excludes works contract services or other composite supplies involving supply of any goods. On the other hand, to qualify to be a supply under serial number 3A above, a composite supply, subject to fulfilment of other conditions as specified in the said entry, would be such that the maximum value of involvement of goods is less than 25% of the total value of the said composite supply.”

The assessee was represented by Indranil Das.

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