2026-VIL-45-AAR
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SGST Advance Ruling Authority

GST – Maharashtra AAR - Classification of Supply as Composite Supply or Mixed Supply - Sections 2(30), 2(74), 2(90) of the CGST Act, 2017 - The applicant is engaged in supplying a bundle of consumables essential for the operation of HP Indigo digital printing presses including ElectroInk, Photo Imaging Plates, Binary Ink Developer, Printing Blankets, Imaging Oil, Blanket Web and other machine products and ancillaries - Whether the supply qualifies as a "composite supply" under Section 2(30) of the CGST Act, with ElectroInk as the principal supply – HELD - The goods supplied by the applicant in a bundled manner cannot be termed to be naturally bundled as envisaged under the definition of Composite Supply. It is only when there is an integrated nexus between the supply of two goods in such a manner that the supply of one good becomes a necessary concomitant for the supply of other goods. In such cases, the supply of such goods would be treated as being bundled in the ordinary course of business - In the instant case, the supply does not qualify as a "composite supply" as the four essential conditions under Section 2(30) are not satisfied. Firstly, while the supply involves two or more taxable goods, the supplies are not "naturally bundled". The bundling of the goods is artificial and specific to the applicant's business model, rather than being the industry norm. The customers have the option to procure the goods separately under the "A-la-Carte" model, which shows the supplies are not naturally bundled. Secondly, there is no single "principal supply" that can be identified, as all the components are equally essential and interdependent for the printing process. The fact that ElectroInk constitutes 41% of the consumption does not make it the principal supply, as the CBIC has clarified that value or volume is not the sole determinant - Merely because certain goods are packaged or sold in a bundle for which a common price is charged does not by itself make supply of such goods a composite supply - The supplies made by the applicant constitute a "mixed supply" under Section 2(74), as the various items can be supplied separately and are not dependent on each other. Consequently, the highest rate of tax applicable amongst the constituent supplies shall apply to the entire supply as per Section 8(b) of the CGST Act – Ordered accordingly - Determination of time and value of supply of ElectroInk with consumables under the indigo press Contract – HELD - The time of supply will be the date of issue of invoice or the date of receipt of payment, whichever is earlier. The value of the supply will be the transaction value as reflected in the tax invoice issued by the applicant in terms of Section 31(4) of the CGST Act.
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