9911796707
TMI Blog2021 (12) TMI 108X X X X Extracts X X X X X X X X Extracts X X X X ..... f Madhya Pradesh (452010). The Applicant is having a GST registration with GSTIN23AAHCR6900N1Z6. 2. The provisions of the CGST Act and MPGST Act are identical, except for certain provisions. Therefore, unless a specific mention of the dissimilar provision is made, a reference to the CGST Act would also mean a reference to the same provision under the MPGST Act. Further, henceforth, for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST or MP GST Act would be mentioned as being under the GST Act. 3. BRIEF FACTS OF THE CASE - 3.1. Riseom Solutions Private Limited manufactures (print) learning kit box whom they call "Class Monitor Home Learning Kit". The so called learning kit is manufactured, market ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to develop various child's skills such as linguistic, logical, sensory & motor, cognitive, creativity, and various other skills. The kitbox/hook contains various sheet for imparting pre-primary education and developing skills of children. * That, the kitbox/book in itself is a complete course, made in such a manner so as to inculcate skills in child along with keeping the child interested in learning by adopting activity-based teaching methodology. The cards, pamphlets and sheets are used to educate the child by using technique of random recognition. * That, the main content of the kitbox/book is the images and pictures, which forms the principal interest in imparting skills to children. * That, the contents of the kithox/book a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... methodology also, wherein instructions are mentioned in the backside of the sheets, and various supporting material to perform these mentioned activities like a craft paper, clips, ribbon, threads, fevicol tube, small sticks, etc are provided therein. * That, referring to the relevant extract of chapter 49 of the GST Tariff as under: Tariff Item Description of goods Unit CGST SGST/UTGST lGST 4903 Children's picture, drawing or colouring books 4903 00 Children's picture, drawing or colouring books: 4903 00 10 Picture Books Kg. NIL NIL NIL 4903 00 20 Drawing or colouring books Kg. NIL NIL NIL And also referring to point no. 6 of Notes of chapter 49, which is reproduced as below "For the purposes of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... plete work and designed for binding. However, printed pictures or illustrations not bearing a text, whether in the form of signatures or separate sheets, fall in heading 4911." On combined reading of aforementioned extract of tariff and HSN 4901. the kitbox/book, which is in the form of separate sheets which are designed for binding (though not bound to maintain the use) could be covered. Further, such separate sheets (being integral part of kitbox/book) have printed pictures but such sheets also bear text, so it could be covered under HSN 4901 and not 4911. * The Applicant also produced a sample of kitbox/book for reference, for determination of rate of tax of supply for which the question has been asked. 7. DISCUSSIONS AND FINDINGS - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arning kit should not be covered under heading 4903 bearing NIL rate of tax. It appears that the said learning kit is more appropriately classifiable in HSN 4901, the relevant extract of GST Tariff is as under :- Tariff Item Description of goods Unit CGST SGST/UTGST IGST 4901 Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets 4901 10 In single sheets, whether or not folded: 4901 10 10 Printed Books U NIL NIL NIL. 4901 10 20 Pamphlets, booklets, brochures, leaflets and similar printed matter U 2.5% 2.5% 5% And also referring to sub point (c) of point no. 4 of Notes to chapter 49 of GST Tariff, which is reproduced as below: "Heading 4901 also covers: (a) a colle ..... X X X X Extracts X X X X X X X X Extracts X X X X
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