with that of printing i.e. the envelopes or tissues or letter cards ad he other goods as the case may be retain their characteristic . even af . ter pnntmg. Th · e h y have stated that in their case the nature of physical mputs is transformed wit the printing activity and without printing the input cannot be used as trae advertising material. In this regard, it is their humble submission that the sd finding of the Hon'ble AAR is legally unsustainable inasmuch as the reasomg does not apply to wallpapers specifically covered under paragraph 5 of th s~1d Circular. In other word s, in the case of wall papers, only on or after pnntmg the specific design, the physical inputs are transformed into wall papers. Hence, their view is that their products which also contain the design and logo of the customers, are more akin to wall papers mentioned in paragraph 5 of the Circular mentioned above. Thus, it is submitted that the case of Appellant is squarely covered under paragraph 5 of the above ref erred Circular, which inter alia provides that wallpaper printed with design, logo etc. supplied by the recipient of goods qualifies as supply of goods. Accordingly, the transaction of supply of trade advertisement material merit being treated as supply of 'goods'. Further, paragraph 4 of the above Circular applies to books, annual reports etc. where the content is voluminous and the owner of this content merely intends printing Setvices thereof. Thus, the Hon'ble AAR by refening to paragraph 4 of the said Circular has mis-applied the same to the facts of the present case.
