JAMIA MILLIA ISLAMIA

Faculty of law

Assignment

MIXED AND COMPOSITE SUPPLY UNDER INDIAN GST LAW

TAX LAW II

Submitted to: Prof. Eakramuddin Malik

Submitted by: Md Maaz Alam

Roll No. - 32

BA.LLB (Regular) 7th Semester

Batch: 2017- 2022

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 ACKNOWLEDGEMENT

I would like to express my gratitude towards my teacher, Prof. Eakramuddin Malik, who
gave me this opportunity to work upon the topic “Mixed and Composite Supply under Indian
GST Law”, and who also helped me with his guidance.

I would also like to thank my parents and friends who helped me in completing this
assignment within the limited time frame.

Md Maaz Alam

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 TABLE OF CONTENTS

 INTRODUCTION..................................................................................4

 CONCEPT OF SUPPLY UNDER GST LAW..................................5

 MIXED AND COMPOSITE SUPPLY.............................................6

 THE EFFECT OF TREATMENT....................................................7

 DISPUTES DUE TO MIXED AND COMPOSITE SUPPLY..........8

 CAR REPAIR ILLUSTRATION......................................................9

 JUDICIAL DECESIONS...................................................................10

 CONCLUSION.................................................................................16

 BIBLIOGRAPHY.............................................................................17

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 INTRODUCTION

The advent of GST has brought about a paradigm shift in the indirect tax regime in India.
Having realized the shortcomings of VAT at the Centre and State level, the Government of
India thought that the introduction of an integrated tax on goods and services in the form of
GST would bring relief to the trade, industry and agriculture. It was felt that the GST would
provide a continuous chain of set off from the original producer’s point and service
provider’s point up to the retailers’ level, and thus would eliminate the burden of tax
cascading.

With these expectations in the background of not so well functioning indirect taxation
system, the GST initiative began in the 21st century. In 2000, the National Democratic
Alliance government formed a committee under the Chairmanship of Mr. Asim Dasgupta
(then West Bengal Finance Minister) to study the feasibility of a GST for India and prepare a
draft GST1. This topic was once again studied by the Task Force on Indirect Taxes and it
gave its report titled ‘A Model and Roadmap for GST in India’ in the financial year 2008-09.2
However, it was only in 2014 that the Government managed to finally get the GST project off
the ground and the bill was passed by the Lok Sabha. Finally, the government launched the
GST on 30th of June, 2017.3 This began a new chapter in the Indirect Taxation system in
India.

This article analyses the concept of composite and mixed supplies, which form a core concept
of the structure of GST law in India. The first section of this article explains the concepts of
composite and mixed supply under the Indian GST law. The second section explains the
possible issues that may arise from the incorrect treatment of composite and mixed supplies.
The third section looks at the treatment of composite supplies in the European Union
(focussing largely on the case law of the European Court of Justice) and Canada, to ascertain
the best practices that may be adopted by India in order to ensure a consistent tax treatment of
such supplies.

1
Manu Balachandran, ‘India’s 16-year wait for the mother of all tax reforms: the Goods and Services Tax’
(Quartz, 3 August 2016) https://qz.com/478650/indias-16-year-wait-for-the-mother-of-all-tax-reforms-thegoods-
2
Finance Commission, Report of the Task Force on Goods & Services Tax, December 15, 2009,
http://www.prsindia.org/uploads/media/Constitution%20122nd/Report%20of%20Task%20Force-%20GST.pdf
3
Vikas Dhoot ‘President to launch GST on midnight of June 30 in Parliament’ (The Hindu, 20 June 2017)
http://www.thehindu.com/news/national/president-to-launch-gst-on-midnight-of-june-30-atparliament/
article19108258.

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 CONCEPT OF ‘SUPPLY’ UNDER GST LAW

Under the law of taxation, a ‘taxable event’ is the event which attracts a tax liability. Taxes
can only be imposed upon the happening of a taxable event.4 GST is imposed on supply of
goods or services, or both,5 and not on the sale or production of the same. In the GST tax
system, tax is collected at every stage of production and the tax paid by a producer at a stage
gets offset by the taxes paid the producers of his input at the preceding stages thus
eliminating the cascading effect of taxation. Thus, the taxable event under the GST
mechanism is supply as defined under the State and Central GST Acts. Deviating from the
State and Central Sales Tax Acts, the term ‘sale’ has been replaced with ‘supply’ in the new
GST Act with sale falling within the scope of ‘supply’.

Section 7(1)(a) of the CGST Act clarifies that all supplies which are made in lieu of a
consideration shall be subject to GST.6 However, the definition is not just restricted to these
but is also inclusive of supply without consideration7 and non-monetary forms of
compensation.8 Moreover, the third schedule deals with transactions, which even though bare
the characteristics of a supply, are not considered so for the purpose of taxation. 9 These
include funeral and cremation services, services provided by elected representatives, courts,
tribunals etc.

A comprehensive list of services and goods has been prepared by the GST council and the tax
rate attracted by each item depends on the category it has been classified under. Calculation
of GST is not an issue when dealing with individual goods or services which have clearly
been identified to be subject to a particular tax rate. However, complexity arises when goods
are packed and sold together as a combination of goods or of services or of both goods and
services. In such a combination, each good attracts a different tax rate. In order to overcome
this difficulty, there are two combinations of goods that have been recognised under GST
mixed supply10 and composite supply11. However, in order to effectively understand the

4
Godfrey Philips India Ltd. v. State of Uttar Pradesh AIR (2005) SC 1103; Kalwa Devadallain v. Union of
India (1963) 49 ITR 165; M. A. Co. v. Assistant Commissioner (1964) 15 STC 487.
5
Constitution of India 1950, art 366(12A).
6
Central Goods and Services Tax Act 2017, s 7(1)(a).
7
Central Goods and Services Tax Act 2017, Schedule I.
8
Central Goods and Services Tax Act 2017, s 7(1)(a).
9
Central Goods and Services Tax Act 2017, Schedule III.
10
Central Goods and Services Tax Act, 2017, s 2(74).
11
Central Goods and Services Tax Act 2017, s 2(30).

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nuances of mixed and composite supply, it is first essential to understand the concept of
bundled supply.

Bundled supply has been defined as “a bundle of provision of various services wherein an
element of provision of one service is combined with an element or elements of provision of
any other service or services”.12 Whether the elements of goods or services or both can be
termed as a bundled supply is dependent on their treatment as the constituent of a single
service. Reliance has been placed on a number of indicators to determine if a set of goods can
be considered to be the constituent of a single service. A few of such indicators are:13

 Perception of the Customer: In case a considerable number of customers have an

expectation that certain goods shall be provided as a package. For instance, selling a
mobile and its charger as a package.
 Nature of the Bundled Service: If one of the services is the primary service while the
others are merely auxiliary or incidental that helps the customer in the better
enjoyment of the principal service. For instance, the principal service of providing
lodging at a hotel is combined with the service of free breakfast or laundry. This
resultant package is treated as services naturally bundled in the ordinary course of
business.
 Industry Practice: If it is a common practice within a particular industry to offer a set
of services as a package. For instance, it is an industry practice of the airline industry
to provide air travel and ancillary services of food and entertainment.

It is important to note that this bundling of services must not affect the character of the
principal service that is being offered. These indicators can be meaningfully relied upon
while determining whether a particular supply falls under the category of a composite supply
or a mixed supply.

Mixed And Composite Supply

When bundling of services either leads to an alteration in the essential character of the
combined supply or makes its identification unfeasible, such a supply is referred to as a
mixed supply. Under GST, if two or more individual goods or services are sold at a single

12
Finance Act 1994, s 66-F.
13
Devanu Choudhury, ‘Understanding Composite Supply Under GST’ (Lakshmikumaran & Sridharan)
https://www.lakshmisri.com/News-and-Publications/Publications/Articles/Tax/understanding-
compositesupplyunder-gst.

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price and such a supply cannot be categorised as composite supply, it is called mixed
supply. 14 For instance, when sweets, cakes, aerated drinks, chocolates etc are sold as a
package for single price, it would constitute a mixed supply. Each of these goods can be sold
separately and is not dependent on each other for their sale. Further, in such a case there is no
means to determine which is the principal good or service giving the essential character to the
package.

In contrast to a mixed supply, a composite supply is based on the concept of bundled goods
and services which has been adopted from the erstwhile service tax regime. Composite goods
have been defined under the GST law as goods “which are naturally bundled and supplied in
conjunction with each other in the ordinary course of business”15 Adding to the requirement
of being naturally bundled, the requirement of the composite supply getting its essential
character from principal good or service can be transposed into the idea of composite
supply. 16 For instance, in the case of IAC Electricals Pvt. Ltd.17, the person had entered into
two contracts, one for the supply of materials and another one for loading/unloading,
insurance and transportation of goods. The services were held to be composite supply as the
contracts were not independent to each other. The same was evident from the terms of the
contract as well.

The Effect on Tax Treatment

This classification of supply into mixed and composite begs the question if the difference
actually has any real consequences on the rate of taxation or is it merely semantic. In cases
where the combined goods fall under the category of composite supply, the rate of tax
applicable to the principal supply will be applicable to the entire package.18 For instance, in
the case of Monsanto Manufacturers Pvt. Ltd. v. CCE19, it was held that cold storage charge
is an inseparable part of a Carrying & Forwarding Agencies’ services with the principal
supply being carrying and forwarding services. Thus, the tax rate applicable on the entire
package would be that applicable to the carrying and forwarding services.

14
Central Goods and Services Tax Act 2017, s 2(74).
15
Central Goods and Services Tax Act 2017, s 2(30).
16
Devanu Choudhury, ‘Understanding Composite Supply Under GST’ (Lakshmikumaran & Sridharan)
www.lakshmisri.com/News-and-Publications/Publications/Articles/Tax/understanding-composite supply under
gst.
17
IAC Electricals Pvt. Ltd. v Joint Commissioner of Commercial Taxes, Kolkata South Circle & Ors.(2017)
M.L. 182 WP No. 30048.
18
Central Goods and Services Tax 2017, s 8(a).
19
Monsanto Manufacturers Pvt. Ltd. v CCE (2013) 65 VST 58 (CESTAT).

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However, in case of a mixed supply, contrary to composite supply, the highest rate applicable
to the goods individually is the rate that shall be applicable to the entire mixed supply. 20 For
instance, in the case of State of Punjab v. Nokia India Pvt. Ltd.21, a cell phone and battery
charger were held to be mixed goods and the tax rate applicable to the cell phone was
applicable to the entire package.

Thus, the most significant distinction between mixed and composite supplies lies in the tax
rate applicable to the respective packages. The tax rate applicable to either of the packages is
significantly different depending on the category they fall in. This classification could
potentially be a major source of litigation and dispute under the GST Law in the country.

DISPUTES DUE TO MIXED AND COMPOSITE SUPPLY

As was noted in the previous section, the possibility of disputes arising out of the distinction
between mixed and composite supplies is immense. The confusion stems from the statute
itself since the phrase “naturally bundled” has not been defined in the CGST Act. The CGST
Act provides the following illustration of a composite supply: “Where goods are packed and
transported with insurance, the supply of goods, packing materials, transport and insurance is
a composite supply and supply of goods is a principal supply.” 22 This example is problematic
since services such as insurance and transportation may not always be “naturally bundled”
with the supply of goods in all cases. This would depend on the contractual obligations
agreed upon between the parties and may therefore vary. 23

Using a hypothetical example of a car repair services, we would like to highlight the varying
interpretations and the consequent dispute that can arise due to lack of clarity on the matter.
This shall be followed by judicial decisions to further emphasise on the real life repercussions
of such a vague distinction, highlighting the urgent need to clarify the concept of naturally
bundled goods.

20
Central Goods and Services Tax 2017, s 8(b).
21
State of Punjab v Nokia India (P) Ltd., (2014) 16 SCC 410.
22
Central Goods and Services Tax Act 2017, s 2(3).
23
Devanu Choudhury, ‘Understanding Composite Supply Under GST’ (Lakshmikumaran & Sridharan)
https://www.lakshmisri.com/News-and-Publications/Publications/Articles/Tax/understanding
compositesupply- under-gst.

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The Car Repair Illustration

Ms. X takes her car to a car repair station due to the noise it was making and the mechanic
replaces a part, and bills her for the new part and his service. Now this transaction can be
classified under various categories, thus affecting the tax rate.

Car Repair as a Service - Composite Supply

When Ms. X went to the mechanic, her primary consideration was for the noise to stop. It
didn’t really matter to her how that is done, whether by changing a part or simply tightening a
loose screw. Thus, Ms. X primarily wanted the service and thus it was the principal supply of
the whole transaction.

Car Repair as a Good – Composite Supply

Ms. X was billed for Y amount for the repair. The bill comprised of two parts- first, the
service rendered by the mechanic and second, the new part accounted for about 75% of the
total bill amount. It can be argued that the principal supply must be determined on the basis
of the value of the total bill. Thus, the supply should be taxed at the rate attracted by the new
part.

Car Repair as a Mixed Supply

In case the bill just has a single amount, it could be argued that both the service of the
mechanic (supply of service) and the new part (supply of good) are equally important for the
noise to stop and thus there is no principal supply. Thus, the service and the part are not
naturally bundled supply and would consequently be classified as mixed supply.

Car Repair as a Segregated Supply

It can be argued that the new part and the service are both equally important and
consequently there is no principal supply. Further, that the value of the goods and services
must be calculated separately on the invoice. The mechanic can combine the charges for the
service and the good in one single invoice but apply different tax rates (the respective tax rate
of each constituent under GST) rather than a single one for the entire package.

Therefore, this illustration highlights how a single transaction can be interpreted and
classified in multiple ways, leading to disputes.

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Judicial Decisions

Although there are very few cases under the new GST law, this inconsistency has already
started to show up in recent rulings. For instance, in In re: M/s Switching Avo Electro Power
Ltd.,24 the question was whether the supply of UPS along with battery at a single price must
be categorised as a composite or mixed supply.

Authority for Advance Ruling, West Bengal ruled as follows:

 It is possible to sell a standalone UPS and its battery separately, and these two
commodities can be purchased by a consumer from different vendors if he/she so
wishes
 It is to be noted that a standalone UPS and battery have different commercial values
as goods, and fall under different tariff heads when sold independently of each other.
 If the combinations of goods being sold do not amount to a composite supply, then
they will be considered to be a mixed supply of goods by implication. 25

Therefore, the above ruling has laid down the principle that a transaction relating to a bundle
of goods would be treated as a composite supply only if such supplies are indivisible in
nature. However, in our opinion, this is a very narrow interpretation of the provision. In fact,
the illustration in the CGST Act itself states that composite supply consists of packing
materials, transport etc, which may be divisible in nature and contracted for separately. 26

In another recent ruling in Samsung (India) Electronics v. Commissioner of Commercial

Taxes,27 it was held that the supply of a charger along with the mobile phone is a composite
supply as there is no intention to affect a separate sale of charger. This clearly seems to
contradict the ruling in In re: Switching Avo Electro Power Ltd., since the charger and the
mobile are certainly divisible and can be sold separately. However, the Court gave paramount
importance to the true intention of the parties. It noted: “One must also bear in mind that in
the case of a composite contract, the true enquiry which must be undertaken is to cull out
what the parties intended to buy and sell.”

24
In re: M/s Switching Avo Electro Power Ltd. (2018) 92 Taxmann 223.
25
Ibid.
26
Indirect Tax Legal Updates’ (Baker Tilly DHC)
www.bakertillydhc.co.in/auth/writereaddata/tender/2505183426Baker%20Tilly%20DHC%20Update%20on%2
0GST%20Advance%20rulings%20May%202018.pdf.
27
Samsung (India) Electronics v Commissioner of Commercial Taxes (2018) 90 Taxmann 92.

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These conflicting decisions and interpretive issues highlight the need for a coherent regime
for determining the fine line between composite and mixed supplies. In this regard, we
suggest that Indian courts can gain valuable lessons from the jurisprudence developed by the
European Court of Justice and Canada with respect to composite supply of products.

Case-by-Case Approach and Focus on the Economic Realities of the Transaction: The

Card Protection Plan Case

The locus classicus of the EU regulation on composite supplies is the Card Protection Plan
case. 28 In this case, the appellant was providing insurance scheme of 'protection and recovery'
plan in case of loss of credit card, car keys, passports, share certificates etc. This was done by
purchasing a block insurance policy from an insurance company and by listing its customers
as assured under the policy. In addition to insurance, other facilitation services like card
registration service, emergency airline ticket, assisting in informing police, lost key location
were provided.

The UK Commission of Customs and Excise held that the activities carried out by Card
Protection Plan Ltd. constituted a basket of ordinary taxable services, which did not include
insurance since there was no direct contractual relationship between the customers and the
insurance company. The appellant however argued that its services constituted an
arrangement for insurance services. In the request for ruling, the ECJ was asked about the
proper test to be applied in deciding whether a transaction consists for VAT purposes of a
single composite supply or of two or more independent supplies.29

The Court provided a fundamental set of rules with regards to composite supplies.

 It noted that in case of bundled goods or services, regards must be had to the
circumstances in which the transaction took place.
 It held that such a supply must normally be regarded as distinct and independent.
However, if a supply comprises of a single service from an economic point of view, it
should not be artificially split.

28
Case C-349/96, Card Protection Plan Limited v Commissioners of Customs and Excise [1999] STC 270 All
ER (EC) 339 (Card Protection Plan).
29
Ibid.

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  For determining this, one needs to look at the essential features of the transaction in
order to ascertain whether a typical consumer is being supplied with several distinct
principal services or with a single service.
 A service must be considered as ancillary if it does not constitute an aim in itself for
the consumers, but is incidental or a means of better enjoyment of the principal
service that is being supplied. 30

Application to Indian Law: Indian law can learn from the pragmatic approach adopted by the
ECJ in a modern economy where the possibility of structuring transactions in specific ways is
limitless. The ECJ has stated that “having regard to the diversity of commercial operations, it
is not possible to give exhaustive guidance on how to approach the problem.” 31 Therefore, the
ECJ has refused to adopt a strict approach but has instead opted for general, open criteria for
interpretation on the basis of the case at hand.

Consideration of “All Circumstances” and the Concept of “Closely Related” Supplies: The
Purple Parking Case and the Brockenhurst College Case

A useful example of the ECJ’s pragmatic approach can be seen in the Purple Parking case.32
In this case, the appellants were two UK companies providing “off-airport park-and-ride”
service, wherein the customers could leave the vehicle at the arrivals area of the car park
which would be subsequently parked by the employees of the car park operators. Further, the
commuter could then take a mini-bus service run by the car park operators themselves, which
would take them straight to the airport terminal. The ECJ was required to decide whether the
services provided constituted a single supply of car-parking service, or of two distinct
services comprising of car-parking and transportation of passengers for the purpose of
taxation. 33

30
Card Protection Plan (n 33), paras 28-30.
31
Card Protection Plan (n 33), para 27.
32
Case C-117/11, Purple Parking Ltd, Airparks Services Ltd v the Commissioners for Her Majesty's Revenue
Service [2012] ECR I-0000 (Purple Parking)
33
Ibid.

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The Court held that the services provided by the appellants comprised of a single supply of
service, wherein parking was the dominant element and the transportation of passengers was
merely ancillary to this primary service. In coming to this conclusion, the court looked at
several factors concerning the business operations of the appellants. It based its finding on the
element of price and its base of calculation. Apart from charging a single price, the appellants
based the price depending upon the time for which the vehicle was kept parked. This clearly
indicated that the primary service sought to be provided was that of car-parking with no
relevance given to the transportation service in the calculation of price. The court noted that
the customers were seeking “first and foremost, parking at an advantageous price.” The
transportation was merely an add-on since the car-park was located at a certain distance away
from the airport terminal.

Apart from the element of price, the Court also looked into the additional services and
marketing strategies adopted by the appellant. In this regard, importance was laid on the
several measures taken to guarantee the safety of the car park, and the fact that this was also
emphasized upon in the appellant’s brochures.34 On the basis of this, it was noted that the
provision of transportation was provided merely to enhance the convenience of the
consumers. From all of these factors, the court concluded that the appellant’s activities
consisted of a single supply of car-parking service, with the transportation of passengers
being merely an ancillary service meant for increased convenience of the consumers.

Application to Indian Law: Indian GST law can gain valuable lessons from the interpretation
of “closely related supplies” under the EU VAT Directive. Article 132(1)(i) of the Directive
ensures exemption from VAT to provisions for “school or university education…including
the supply of services and of goods closely related thereto…”35 In this regard, a case decided
very recently by the ECJ again is worth considering. In Brockenhurst College 36 case, the ECJ
was required to decide whether the provision of restaurant and entertainment services by the
college to its students, constituted a service closely related to the purpose of university
education, and therefore exempt.

34
Purple Parking (n 37), paras 33-36.
35
Council Directive (EC) 112/2006 on the common system of value added tax, art 132(1)(i).
36
Case C-699/15, Her Majesty’s Revenue and Customs v Brockenhurst College, [2017] EUECJ (Brockenhurst
College) Brockenhurst.

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The ECJ noted that the relevant consideration should be as to whether the services provided
were essential for the education of students, and whether their primary motive was to
generate additional income or to provide service to the students. The court delved into the
factual matrix of the case and observed that the college offered courses in catering and
hospitality, and one of the purposes of the restaurant was for the students to enhance their
skills and give them a real time experience. 37 From this, the court concluded that the
restaurant was not run for making profits, and therefore the “principle of fiscal neutrality”
had not been violated. Hence, it was held that these services qualify as a closely related
supply.

While arriving at its decision, the Court propounded three fundamental conditions to
determine as to whether a supply is a ‘closely related’:

1. It ‘relates to’ and is ‘closely linked’ to the primary supply

2. It is actually supplied as an ancillary to the primary supply
3. It does not constitute an end in itself, but merely a means to an end.

This concept of ‘closely related’ supplies under EU law is similar to that of ‘ancillary’ supply
under the CGST Act. Since there is no guidance provided for drawing the distinction between
‘principal’ and ‘ancillary’ supplies, these parameters laid down by the ECJ can be
pragmatically used in the Indian context.

This “reality-based approach” taken by the ECJ has been successful in creating a well thought
jurisprudence in the field of composite supplies. It is suggested that the application of GST
law in India should also provide for such flexibility on the basis of the facts of the case,
instead of following a straightjacket formula.

Application to Indian Law: This case is a fine illustration of the Canadian treatment of
composite supplies, which focuses on both the perspective of the consumer and the
supplier. 38 From the consumer’s perspective, the main motive behind the lease was the
enjoyment of the residential facilities. Moreover, the supplier’s primary interest lied in
leasing the residential lots with the facilities being an additional incentive towards this end.

37
Brockenhurst College, para 33.
38
Stefano Conese, ‘The EU VAT Treatment of Composite Supplies: Evolution Trends and Critical Points’
(2017) Tilburg University Research Paper 1/2017.

14
This approach is in contrast to that of the ECJ, which has generally tended to favour the
consumer’s standpoint.39

Therefore, Indian law can adopt the Canadian approach of employing both the consumer and
supplier’s perspectives as the fundamental benchmarks of analysis. In other respects,
Canadian law tends to overlap with the EU’s treatment of composite supplies.

Thus, both the EU and Canadian law recognise the practical challenges of composite
supplies, and provide the much-needed economic flexibility while at the same time providing
for a minimum degree of legal certainty.

39
Card Protection Plan (n 33), para 44.

15
 CONCLUSION

The GST Network has enabled the linkage of vast industries and markets into a common
platform, and has vastly simplified the tax regime operating in the country through the
creation of a national common market. However, as we have seen over the course of this
article, the concept of supply under GST law can pose problems in cases of bundled goods
and services. The complex commercial transactions continuously test and strain the bounds of
tax laws. To ensure the longevity of a system like the GST, it is essential to ensure that the
regime is consistent in its treatment of different goods and services, and there is minimum
confusion among the suppliers and consumers.

Given the categorisation of supplies as mixed supply and composite supply under GST,
businesses will need to relook all their potential bundled goods and services. Further, tax
authorities and courts will be confronted with difficult factual circumstances concerning the
treatment of bundled goods and services. Due to the differential tax treatment under the GST
law of composite and mixed supplies, this categorisation becomes crucial for businesses.

Therefore, it is important to clearly understand composite supply and mixed supply, their tax
implications and accordingly operate to fulfil the desired objective of bundling goods and
services.

In this regard, this article has looked at the jurisprudence of the European Court of Justice
and Canadian courts with respect to their treatment of composite supplies. It is noticed that
these jurisdictions have developed coherent and practical guidelines in this respect, which can
be suitably adopted by Indian courts as well. Specifically, it is crucial that Indian courts
develop general guidelines for drawing the distinction between composite and mixed
supplies, which can be subject to a case by case analysis. As has been noted by the ECJ, it is
essential that all the circumstances of the transaction are looked at to form the bigger picture,
and to ascertain whether the supply constitutes a single supply or a group of distinct supplies.

Thus, we see that even though GST regime is a dynamic step towards a coherent and
progressive tax regime for India, certain lacunae need to be filled by the legislature in terms
of providing certainty.

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 BIBLIOGRAPHY

Books:

 V.S. Datey: Indirect Taxex Law and Practice, Taxman Publications, New Delhi.

 Vikas Mundra, Tax Laws, Law Point Publications, Kolkatta.

Websites:

 www.bakertillydhc.co.in/auth/writereaddata/tender/2505183426Baker%20Tilly%20

DHC%20Update%20on%20GST%20Advance%20rulings%20May%202018.pdf.

 https://cleartax.in/s/mixed-composite-supply-gst

 https://www.cbic.gov.in/resources//htdocs-

cbec/gst/51_GST_Flyer_Chapter4.pdf;jsessionid=47D387A920A75E6ABF5A49FB3

ECDB276

 https://gstindiapro.com/2020/05/29/composite-supply-and-mixed-supply/

 https://taxguru.in/goods-and-service-tax/composite-supply-mixed-supply-section-8-

cgst-act-2017.html

 http://gstsutra.com/experts/column?sid=549

 https://www.consultease.com/gst-compliances-in-india/concept-of-mixed-supply-

composite-supply-under-gst/

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