2025-VIL-206-AAR
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SGST Advance Ruling Authority

GST – Gujarat AAR - Section 2(30) and Section 2(90) of the CGST Act, 2017 - Composite Supply vs. Mixed Supply - The applicant plans to provide sachets of instant Premix Tea as an introductory offer along with its various tea products - Classification of supplies where the applicant intends to provide sachets of its "Jivaraj Samaara Masala Instant Premix Tea" along with its other tea products as an introductory offer - Whether such bundled supplies would be considered as "Composite Supply" or "Mixed Supply" – HELD – The bundling of premix tea with other tea is not the perception of the customer as the customer does not expect any such bunching when he buys tea. The premix tea is not an ancillary commodity which is required to be supplied with the other tea. The premix tea and the other tea is not normally advertised as a package. It is only for testing the market that the applicants have decided to bunch it with the other tea. Further, the premix is not integral to the overall supply such that if it is removed the nature of the supply is affected - The various indicators to ascertain whether the supplies are naturally bundled, such as consumer perception, industry practice, and the nature of the supplies, are not present in the instant case. Therefore, the supply of Instant Premix tea with other tea will not constitute a composite supply - The bundled supplies would be considered as "Mixed Supply" and not "Composite Supply" as the premix tea and the other tea products are not naturally bundled and supplied in conjunction with each other in the ordinary course of business - Since the GST rate on all the tea products, including the premix tea, is 5%, the rate of tax for the "Mixed Supply" would also be 5% and any of the HSN codes of the supplies in the mixed supply can be used, as long as the tax rates are the same – Ordered accordingly
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