GST on Printing Services: Kerala AAR Clarifies Classification Under SAC 9988 and SAC 9989 for Job Work and Religious Book Printing

Background and Nature of the Applicant's Business

The Kerala Authority for Advance Ruling examined the GST implications arising from the printing activities carried out by M/s. Ebenezer Printpack Private Limited (GSTIN: 32AACCE1999P1ZP), a Kerala-based private limited company engaged in providing a range of printing services. The company prints brochures, leaflets, pamphlets, diaries, danglers, booklets, multicolour labels, posters, and various other printed materials for its clients.

The applicant's operations are structured under two distinct arrangements, each involving a different configuration of ownership over the principal inputs — namely, the paper and the content to be printed. These two arrangements raise separate and important questions under GST law, which the Authority addressed in turn.

Issue 1 — Printing on Customer-Supplied Paper and Content

Factual Matrix

Under the first operational model, the customer supplies both the paper and the content intended to be printed. The applicant's own contribution in this arrangement is limited to consumables such as ink, chemicals, plates, and similar materials that are incidental to the printing process. At no point does the ownership of either the paper or the finished printed output transfer to the applicant — ownership of both remains with the customer throughout.

The printed output in such cases typically includes brochures, pamphlets, labels, periodicals, booklets, and other commercial printed materials.

To determine how this activity is to be treated under GST, the Authority examined Section 2(68) of the CGST Act, 2017, which defines "job work" as:

"Job work means any treatment or process undertaken by a person on goods belonging to another registered person."

A critical observation made by the Authority is that the definition expressly requires the goods to belong to another registered person. Accordingly, where the treatment or process is performed on goods belonging to an unregistered person, the activity falls outside the scope of job work as defined under Section 2(68) of the CGST Act, 2017.

Since the applicant did not specify in its application whether the customers supplying the paper and content are registered or unregistered under GST, the Authority concluded that whether the activity qualifies as "job work" is contingent upon the GST registration status of the recipient. The classification will thus vary on a case-to-case basis.

SAC Classification: Heading 9988

Regardless of the registration status of the customer, the Authority held that the activity — being a treatment or process carried out on goods owned by another person — is classifiable under SAC 9988: Manufacturing services on physical inputs (goods) owned by others, as listed under Entry No. 26 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017.

Applicable GST Rate Under Entry No. 26

The Authority undertook a detailed analysis of Entry No. 26 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017, as amended by Notification No. 15/2025-Central Tax (Rate) dated 17.09.2025. The relevant structure of the entry distinguishes between:

Concessional Sub-entries attracting 5% GST:

  • **Sub-entry (ii)😗* Services by way of job work, including:
    • Clause (e): Printing of newspapers, books (including Braille books), journals and periodicals
    • Clause (f): Printing of all goods falling under Chapters 48 or 49 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) which attract central tax @2.5% or Nil