12. Write a note on Tax liability on composite and mixed supplies?

The Goods and Services Tax (GST) regime in India revolutionized the country’s indirect tax structure by subsuming multiple state and central taxes into a single, unified system. However, with this integration came new definitions and tax rules—two of the most important being “composite supply” and “mixed supply.” Understanding the tax liability on composite and mixed supplies is crucial for businesses and professionals to comply with GST norms and avoid legal pitfalls.

This article offers a humanized, SEO-friendly explanation of these concepts as per CGST Act, 2017, including definitions, real-life examples, tax treatment, and a helpful mnemonic at the end to remember the differences and tax rules.


What Is Meant by Supply under GST?

Under Section 7 of the CGST Act, 2017, “supply” includes all forms of supply of goods or services such as sale, transfer, barter, exchange, license, rental, lease, or disposal made for a consideration in the course or furtherance of business.

Supply is the taxable event under GST, and understanding whether a supply is composite, mixed, or independent is crucial in determining the appropriate GST rate and compliance responsibility.


Definition of Composite and Mixed Supply under GST

1. Composite Supply – Section 2(30) of CGST Act

“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.”

Key Characteristics:

  • Naturally bundled (go together in normal business practice)
  • Supplied together
  • One supply is dominant (principal), others are ancillary

Examples:

  • Supply of air travel with onboard meals (main supply: air transport)
  • Sale of a smartphone with charger (main supply: phone)
  • Renting of furnished accommodation (main supply: renting)

Tax Implication:

  • GST rate applicable on the principal supply will be charged on the entire composite supply.

2. Mixed Supply – Section 2(74) of CGST Act

“Mixed supply means two or more individual supplies of goods or services, or any combination thereof, made in conjunction with each other for a single price, which do not constitute a composite supply.”

Key Characteristics:

  • Not naturally bundled
  • Supplied together for a single price
  • Each item can be supplied independently

Examples:

  • Gift hamper with chocolates, perfumes, and cosmetics (each item is distinct)
  • Diwali gift pack with sweets, LED lamp, and dry fruits
  • Combo offer of shampoo + toothpaste + comb for one price

Tax Implication:

  • Highest GST rate among the items in the supply will be charged on the entire mixed supply.

How to Determine Whether a Supply Is Composite or Mixed?

The “bundling test” is used:

  • If items are naturally bundled and used together in the course of business, it is composite.
  • If the items are artificially bundled only for promotional or pricing strategy, and can be sold separately, then it is mixed.

Real-Life Examples of Composite vs Mixed Supply

ScenarioType of SupplyPrincipal SupplyTax Liability
Buying car with insurance and registrationComposite SupplyCarGST on car charged on total price
Hotel accommodation with complimentary breakfastComposite SupplyHotel stayGST rate of accommodation applies
Combo pack of soap, shampoo, and toothbrushMixed SupplyNone (each is distinct)Highest GST rate among items is applied
Sale of air ticket with meal and baggageComposite SupplyAir travelGST on air travel applies to entire value
Hamper with wine, chocolates, and beauty productsMixed SupplyNoneHighest GST rate on any item in hamper

Why Understanding These Supplies Matters

Businesses must correctly classify supplies because:

  • Wrong classification can lead to excess or short tax payments
  • May result in penalties and interest for non-compliance
  • Ensures accurate invoicing and tax credit utilization
  • Helps in customer pricing strategies and tax planning

The correct tax liability ensures legal compliance and builds customer trust.


Tax Liability Summary

Type of SupplyBundled NatureTax Rate Applicable OnLegal Section
Composite SupplyNaturally bundledPrincipal supplySection 2(30), CGST Act
Mixed SupplyArtificially bundledHighest GST rate among itemsSection 2(74), CGST Act

Additional Points to Consider

  • Separate Invoicing can help avoid mixed supply treatment if items are billed separately.
  • Offers and Promotions should be carefully structured to avoid unintended higher tax implications.
  • For B2C businesses, combo deals should be reviewed to ensure that bundled products do not fall under mixed supply by default.

Mnemonic to Remember – “CAMP”

Use the mnemonic “CAMP” to easily remember the difference between Composite and Mixed Supplies and their tax treatment:

  • CComposite = Common business bundle
  • AApply tax of principal supply
  • MMixed = Multiple independent items
  • PPay tax at the highest rate

This simple phrase helps GST practitioners, business owners, and students recall the essential classification rules.

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