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Microlesson · 5-min read

Composite Supply [Section 8 read with Section 2(30)]

# Composite Supply [Section 2(30)]

## Definition

A composite supply is a supply made by a taxable person to a recipient which:

1. Comprises two or more taxable supplies of goods/services/both, or any combination thereof.

2. Is naturally bundled and supplied in conjunction with each other in the ordinary course of business.

3. One of which is a principal supply.

## Principal Supply [Section 2(90)]

The supply of goods/services which constitutes the predominant element of a composite supply and to which any other supply forming part is ancillary.

## How to Identify 'Naturally Bundled in Ordinary Course of Business'?

It depends on normal/frequent practices in that business area. Indicators include:

### 1. Consumer Perception

If a large number of recipients reasonably expect such services as a package.

  • E.g., a mobile phone is always sold with a battery.

### 2. Industry Practice

Majority of service providers in the area offer a similar bundle.

  • E.g., catering on board + air transport is bundled by most airlines.

### 3. Nature of the Bundle

One service is the main service; others are incidental/ancillary, enhancing enjoyment of the main service.

  • E.g., hotel stay + complimentary breakfast and dinner – meals are ancillary to accommodation.

### 4. Other Illustrative Indicators (indicative, not determinative)

  • Single price charged irrespective of which components consumer uses.
  • Elements are advertised as a package.
  • Different elements are not available separately.
  • Different elements are integral to one overall supply – removing one affects the nature.

## Tax Treatment [Section 8(a)]

  • A composite supply is treated as a supply of the principal supply.
  • Entire value is taxed at the rate applicable to the principal supply.

## Important Clarifications

### Printing Industry

  • Printing of books/pamphlets where content is owned by publisher and physical inputs (paper) belong to printer → Supply of printing is principal supply → Supply of SERVICE.
  • Printing of envelopes/letter cards/boxes where printer uses its own physical inputs to print recipient's design/logo → Supply of goods is predominant → Supply of GOODS.

### Healthcare

  • Food to in-patients as per doctor/nutritionist advice → part of composite healthcare → not separately taxable.
  • Food to out-patients/attendants/visitors → taxable separately.

### Bus Body Building

  • Involves both goods and services. Classification depends on which is principal supply – determined case by case.

### Retreading of Tyres

  • If old tyres belong to customer → composite supply of SERVICE (retreading process is principal).
  • If old tyres belong to supplier of retreaded tyres → supply of GOODS.

### Cinema Halls – Food & Beverages

  • F&B in cinema halls is taxable as 'restaurant service' IF: supplied independent of cinema exhibition AND as part of a service.
  • If cinema ticket and F&B are sold together as composite supply → GST at rate applicable to cinema exhibition service.

Worked example

### Example 1

Example 1 (5-Star Hotel Conference): Hotel offers a bundled service: accommodation + meals + amenities for conference delegates. → Composite supply; principal supply = convention service.

### Example 2

Example 2 (Readymade Shirts in Designer Box with Transit Insurance): Poshaak supplies shirts in designer boxes + transit insurance. → Composite supply; principal supply = supply of goods (shirts).

### Example 3

Example 3 (TV with Mandatory Warranty): Sale of TV with mandatory warranty/maintenance. → Composite supply; principal = TV (goods).

### Example 4

Example 4 (Air Ticket): Mumbai-Delhi air ticket includes food + insurance + lounge access. → Composite supply; principal = transport of passengers.

### Example 5

Example 5 (Cinema): A cinema sells a 'Movie + Popcorn' combo ticket for ₹500. → Composite supply taxable at the GST rate of cinema exhibition service. If popcorn is sold separately at the kiosk → taxable as restaurant service.

⚠️ Common exam mistakes

  • Applying composite supply treatment to items that are independent and not naturally bundled.
  • Identifying the wrong supply as 'principal' – it must be the predominant element, not the highest-value element.
  • Assuming all 'package deals' are composite supplies – check for natural bundling in the ordinary course of business.
  • Treating food to out-patients as part of composite healthcare – it is separately taxable.
Bare-Act text Sections 2(30), 2(90), 8(a) · CGST Act, 2017 · click to expand
Section 2(30): 'composite supply' means a supply made by a taxable person to a recipient consisting of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply. Section 8(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.
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