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Microlesson · 5-min read

Composite Supply and Mixed Supply [Section 8]

# Composite Supply and Mixed Supply [Section 8]

## Why this matters

When a single transaction bundles two or more supplies (goods, services, or a mix), GST law needs a rule to decide what rate to apply. Section 8 provides that rule by classifying bundled transactions as either Composite Supply or Mixed Supply.

## 1. Composite Supply

A supply is composite when all three conditions are met:

1. There are two or more supplies (goods, services, or both).

2. They are naturally bundled and supplied together in the ordinary course of business.

3. One of the supplies is the principal supply (the predominant element).

Key terms

  • Naturally bundled → The combination is normal in that line of business (test: would a customer typically expect to receive these together?).
  • Principal supply → The dominant element around which the other supplies are ancillary.

## 2. Mixed Supply

A supply is mixed when:

  • Two or more supplies are made together for a single price, and
  • It does not qualify as composite supply (i.e., not naturally bundled / no principal supply).

## 3. Tax Treatment — The Decisive Table

TypeTax Rate to Apply
Composite SupplyRate applicable on the principal supply
Mixed SupplyHighest rate among all supplies in the bundle
Separately priced items (not composite)Respective rate for each item

## 4. Quick Decision Flow

```

Is there a single price? → No → Tax each item at its own rate

↓ Yes

Are supplies naturally bundled + principal supply identifiable?

↓ Yes → Composite → Rate of principal supply

↓ No → Mixed → Highest rate

```

## 5. Special Circulars

### (a) Printing Industry

TransactionNatureReason
Printing books, pamphlets, annual reports, brochuresSupply of ServiceIntellectual property (content) dominates
Printing napkins, tissues, letterheads, envelopesSupply of GoodsPaper (physical good) dominates

### (b) Food & Beverages in Cinemas

SituationTreated As
F&B sold independent of cinema ticketRestaurant service
F&B bundled with cinema exhibition serviceCinema exhibition service (composite)

### (c) Tenancy Right (Pagdi System)

  • Transfer of tenancy right against tenancy premium = supply of service (taxable). Liability to stamp duty does not change this.
  • Service by owner (tenancy premium) → Taxable.
  • Exception: If the dwelling is residential and let to an unregistered person (or registered proprietor using it personally), rent is exempt → tenancy premium also Exempt.
  • Service by outgoing tenant (surrendering tenancy right) → Taxable.

Worked example

### Example 1

Example 1 — Transportation with loading/unloading

A Ltd. provides transportation services to Mr. Jack along with loading and unloading.

→ Naturally bundled (loading is incidental to transportation).

Composite Supply; principal supply = transportation.

→ Apply the transportation rate to the entire value.

### Example 2

Example 2 — Hotel accommodation with breakfast

Clark Hotel charges ₹5,000/night for room + breakfast (single price).

→ Naturally bundled; principal = accommodation.

Composite Supply; tax the full ₹5,000 at the accommodation rate.

### Example 3

Example 3 — Gift basket of chocolates + dry fruits

Sweet shop sells a basket of chocolates + dry fruits for ₹1,000.

→ NOT naturally bundled (sold together only for the gift occasion).

Mixed Supply; charge ₹1,000 at the highest of the two GST rates.

### Example 4

Example 4 — Printing of an annual report

A printer prints a company's annual report using its own paper.

→ Content (IP) is dominant.

→ Classified as supply of service → service rate applies.

### Example 5

Example 5 — Pagdi premium for a flat let to an unregistered tenant

Owner receives tenancy premium for a residential flat let to an unregistered tenant for residence.

→ Rent itself is exempt → Tenancy premium is also Exempt.

⚠️ Common exam mistakes

  • Treating any bundled supply as composite — forgetting the 'naturally bundled in the ordinary course of business' test.
  • Confusing 'predominant by value' with 'principal supply' — principal supply is the predominant element/purpose, not necessarily the costliest line item.
  • Applying the highest rate to a composite supply (highest-rate rule is for MIXED supply only).
  • Applying composite/mixed rules when prices are separately quoted — separately priced items are taxed at their own respective rates.
  • Assuming printing transactions are always 'service' — napkins, tissues, envelopes are supply of GOODS because paper dominates.
  • Treating pagdi premium as non-taxable because stamp duty is paid — stamp duty has no bearing on GST chargeability.
  • Missing the residential-dwelling exemption carve-out for tenancy premium (premium follows the rent treatment).
Bare-Act text Section 8 · CGST Act, 2017 · click to expand
Section 8 of the CGST Act — Tax liability on composite and mixed supplies: The tax liability on a composite or a mixed supply shall be determined in the following manner, namely — (a) a composite supply comprising two or more supplies, one of which is a principal supply, shall be treated as a supply of such principal supply; and (b) a mixed supply comprising two or more supplies shall be treated as a supply of that particular supply which attracts the highest rate of tax.
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