Maharashtra AAR Clarifies GST Classification for Printing and Supply of Books Based on Content Ownership

Mumbai, 27 February 2026: The Maharashtra Authority for Advance Ruling (AAR) has delivered a comprehensive ruling on the GST classification and applicable tax rates for various supplies made by the Maharashtra State Bureau of Textbook Production & Curriculum Research. The ruling addresses the tax treatment of printing and supplying textbooks, large print books, online admission booklets, and other educational publications, with a central focus on the ownership of the content being printed.

Background and Issues: The applicant, an autonomous body established for textbook production and curriculum research, sought advance rulings on whether its diverse activities—ranging from printing textbooks in various languages to supplying special editions and non-textbook publications—constitute supply of goods or services under the GST regime, and the applicable tax rates. The applicant highlighted scenarios where it either owns the content or merely prints content provided by government authorities or other entities.

Legal Framework and Submissions: The AAR examined relevant GST notifications, CBIC Circular No. 11/11/2017-GST, and prior advance rulings from other states. The key distinction drawn was based on the ownership of the intellectual property in the content:

• If the applicant owns the content and supplies the printed books, the transaction is classified as a supply of goods under HSN 4901, which is exempt from GST as per Notification 2/2017-CT (Rate).
• If the content is provided by another party (such as a government department) and the applicant only undertakes the printing, the transaction is classified as a supply of services under SAC 9989, attracting 18% GST.

The AAR also clarified that job work provisions (with a 5% GST rate) apply only when physical inputs are supplied by another registered person, which was not the case in the applicant’s scenarios.

Court’s Analysis and Findings: The AAR systematically analyzed each category of supply:

• Printing of textbooks in other languages (e.g., Tamil, Bengali): Where the applicant does not own the copyright and only prints the books, the supply is treated as a service under SAC 9989, taxable at 18% GST.
• Big books/large print textbooks for visually impaired students: If the applicant owns the content, the supply is exempt as goods under HSN 4901. If not, it is a service under SAC 9989, taxable at 18%.
• Online admission booklets: As the content is provided by the Directorate of Education, the supply is a service under SAC 9989, attracting 18% GST.
• Open book sales and non-textbook publications: Where the applicant owns the content, the supply is exempt as goods under HSN 4901. Where content is owned by others, it is a service under SAC 9989, taxable at 18%.
• Special editions and books supplied on government orders: If the content is not owned by the applicant, the supply is a service under SAC 9989, taxable at 18%.

The AAR emphasized that the principal supply—goods or services—must be determined by the ownership of the content and the nature of the transaction, in line with the CBIC circular and relevant GST notifications.

Final Ruling: The AAR answered each of the applicant’s queries, reiterating that:

• Supplies where the applicant owns the content are classified as goods under HSN 4901 and are exempt from GST.
• Supplies where the applicant only prints content provided by others are classified as services under SAC 9989 and attract 18% GST.

This ruling provides much-needed clarity for educational publishers and government bodies engaging in similar transactions, ensuring consistent GST treatment based on content ownership and the nature of supply.