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2019 (12) TMI 1118 - AAR - GSTClassification of supply - procurement of advertisements for the Directory - bundles services or intermediary services or mixed supply - whether classifiable as selling of space for advertisement in print media? - applicability of SI No. 21 (i) of N/N. 11/2017 - CT (Rate) dated 28/06/2017 (corresponding State N/N. 1135FT dated 28/06/2017), as amended from time to time. HELD THAT:- Selling of space for advertisement, when made as an intermediary, is classifiable under SAC 998362, which excludes sale of advertising space in print media (SAC 998363) and is taxable @ 18% under SI No. 21 (ii) of the Rate Notification - Service by way of printing (SAC 998912) of all goods falling under Chapter 48 or 49 of the First Schedule of the Customs Tariff Act, 1975 (where the physical inputs are supplied by the printer) is taxable @ 12% under SI No. 27 (i) of the Rate Notification. The mixed supply of the Applicant should, therefore, be treated taxable under SI No. 21 (ii) of the Rate Notification. The Applicant is making a mixed supply to the Tollygunge Club of printing service (SAC 998912) and intermediary service for selling space for advertisement on behalf of the club (SAC 998362). It shall be treated as supply of the above intermediary service taxable @ 18% under SI No. 21 (ii) of Notification No. 11/2017 - CT (Rate) dated 28/06/2017 (corresponding State Notification No. 1135FT dated 28/06/2017), as amended from time to time.
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