The Appellant sought an advance ruling under section 97 on the following questions: 1. whether the job of printing of content provided by the customer taxguru.in on polyvinyl chloride banners and supplying such printed trade advertisement material amounts to supply of goods, and 2. What is the classification of such trade advertisement material under GST Tariff if the transaction is a supply of goods.

The WBAAR in its Ruling No. 15/WBAAR/2019-20 dated 19.08.2019, observed inter alia, that the transaction involves a composite supply — a transaction involving both supply of goods in the form of printed PVC material and of the service of printing the content provided by the recipient, which are inseparable in the execution of the contract. According to the WBAAR, the printed trade advertisement material has no utility other than displaying the printed content. It held that the service of printing is the predominant element of the composite supplies the Appellant is making. Thus, the WBAAR held that the goods classifiable under Chapter 39 and 49 of Customs Tariff Act, 1975 (hereinafter referred to as the “Tariff Act”) are supplied by the appellant but the supply of the said items are ancillary to the principal supply of printing service. The Appellant has filed the instant Appeal against the above Advance Ruling with the prayer to set aside/modify the impugned Advance Ruling passed by the WBAAR or pass any such further orders as may be deemed fit and proper in the facts and circumstances of the case. The Appellant argued that the product description in their invoice is mentioned as “Printing and Supply of Trade Advertisement Material HSN#4911”, because what they supply are primarily goods.