17.09.2022: 12% GST would be payable on supply of services for printing on duplex board including cutting, punching, and lamination of the board: West Bengal AAR

The West Bengal Authority of Advance Ruling (AAR) in the case of Anamika Agrawal vide Order No. 09/WBAAR/2022-23 dated 18.08.2022, held that the supply of services for printing on duplex board belonging to the recipient, including cutting, punching, and lamination of the duplex board, so printed, would attract 12% GST (6% CGST and 6% WBGST) irrespective of whether the recipient of the services is registered under the GST Act or not.

In this case, the applicant is in the business of manufacturing printed boxes, mono cartons, labels, etc., and also undertakes work contracts of the same nature. In the process of work contract, the applicant receives only a duplex board from its customer, on which the applicant undertakes the work of printing, lamination, punching, cutting, and other related activities.

The applicant has sought an advance ruling in respect of the applicability of the GST rate on work contracts (job work). The applicant submitted that it has been clarified in Circular 126/45/2019-GST dated 22.11.2019 that job work services supplied to a registered person would attract 12% tax and 18% GST will be applicable when provided to an unregistered person. The applicant accordingly charges tax at 12% on job work services provided to registered persons and at 18% on job work services provided to unregistered persons.

The West Bengal AAR observed that the activities of printing on duplex boards belonging to its customer, including cutting, punching, and lamination, as and when required by the customer, shall be treated as services by way of job work.

The AAR stated that any treatment or process performed on goods owned by another person shall be considered “job work” if the goods are owned by a registered person. In other words, when goods are owned by a person who is not registered, it shall not be regarded as job work.

The Authority ruled that Chapter 48 of the Customs Tariff Act specifies paper and paperboard; articles of paper pulp of paper or of paperboard. Duplex board, being a form of paper board, falls under Chapter 48 and attracts 12% GST.

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