Lab manual comprising educational material is to be classified as printed books and not exercise book: AAR Punjab

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Fact: M/s Evergreen Publication (India) Ltd, is manufacturing the Lab Manuals called “Books” printed/published in accordance with the specified syllabus issued by CBSE for class VI to class XII which is written by the authors as per prescription by Educational Boards. It comprises of the entire syllabus of the practical subject described and consists of the comprehensive study material covering syllabus, questions/answers part & some leafs for the use of the students.

Issue Involved: whether the Lab manuals generally for class 6th to 12th printed by printing/publishing industry as prescribed by education boards & written by author(s), is a tax-free product falling under heading 4901 attracting nil duty.

Held: The Hon’ble AAR of Punjab vide Advance Ruling no. AAR/GST/PB/004/2018 dated August 13, 2018 observed as under:

Printed Book under Heading 4901 read as: Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets. (A) Books and Booklets consisting essentially of textual matter of any kind, and printed in any language or characters, including Braille or shorthand. They include literary works of all kinds, text-books (including educational workbooks sometimes called writing books), with or without narrative texts, which contain questions or exercises (usually with spaces for completion in manuscript); technical publications; books for reference such as dictionaries, or without printed instructions, for completion by drawing or colouring, sometimes cultured illustrations for guidance are incorporated. They also include similar books with “invisible” outlines or colour which can be made visible by rubbing with a pencil or applying water with a paint brush, and also books in which the small amounts of water colour required for colouring are contained in the books (e.g., in the form of a palette)”

Whereas Exercise book under Heading 4820 read as: “These may simply contain sheets of lined paper but may also include printed examples of handwriting for copying in manuscript” e.g. diaries, exercise books, there may be considerable amount of printed matter, but the printing is incidental to their primary use of writing by hand.

On the basis of inter-alia above findings the AAR pronounced that, Lab Manual being published by the applicant which comprises bulk of instructional /educational printed material as per syllabus of Educational Board and which also contains some blank pages for the students to practice or write, would be classified under GST Tariff heading 4901 as printed books which currently carry a Nil rate of tax. Because it is observed that the main feature which differentiates ‘Work Books’ of heading 4901 from the ‘Exercise Books’ of heading 4820 is that whereas the ‘Work books’ of heading 4901 contain questions or exercise with space for writing the answers whereas, the ‘Exercise Books’ of heading 4820 contain printed texts with space for copying manually.

Citation: [2018] 98 239 (AAR-PUNJAB)