2026-VIL-170-AAR
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SGST Advance Ruling Authority

GST - Telangana AAR - Applicable rate of tax on leasing of Digital Cinema Equipment comprising Projector, Server, UPS and VSAT - Applicant, engaged in leasing Digital Cinema Equipment to theatres, provided four different equipment's, namely Projector, Server, UPS and VSAT, each bearing a different HSN, and charged lease rental for the entire set in a single invoice - Applicant contended that the supply is a mixed supply under Section 8, and that the HSN attracting the highest rate of tax would apply to the entire supply - Whether the supply constitutes a composite supply or a mixed supply under Section 8 of the CGST Act, 2017 - HELD - As per Section 2(30) of the CGST Act, a composite supply requires two or more taxable supplies that are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply - Applying the indicators for ascertaining natural bundling, none of the indicators are satisfied. The supply of Digital Cinema Equipment does not constitute a composite supply - As per Section 2(74) of the CGST Act, a mixed supply requires that the bundled supply not be a composite supply, have a single price, and that each item be capable of being supplied separately though not actually supplied separately. The equipment is leased together for a single lease rental and is not supplied separately, and is not naturally bundled. The supply of Digital Cinema Equipment therefore falls under the ambit of mixed supply - As per Section 8(b) of the CGST Act, a mixed supply comprising two or more supplies is treated as a supply of that particular supply which attracts the highest rate of tax - Among the equipment's comprising the Digital Cinema Equipment, the Projector bearing HSN 8528 attracts the highest rate of tax, and therefore the GST rate applicable to the Projector applies to the entire mixed supply - The applicable rate of GST on the mixed supply of Digital Cinema Equipment is held to be 28% upto 21.09.2025 and 18% thereafter – Ordered accordingly
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