Car parking rights are a separate taxable supply, not part of composite construction service, even after completion certificate.

Right to use car parking space, when offered with under-construction apartments, was treated as a separate taxable supply because it was optional, separately priced, and capable of being availed independently by a flat purchaser. The composite supply test under section 2(30) was not met, as the parking facility was not a naturally bundled ancillary element of construction service and did not share the principal supply character. Completion of the apartment transaction did not change the tax treatment of the parking supply, and the cited clarification on preferential location charges in a long-term land lease was held inapplicable to this distinct service.

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Issues: Whether the amount charged for right to use car parking space along with sale of under-construction apartments constitutes a composite supply of construction service, and whether such parking charges remain taxable when the apartment is sold after completion certificate or when the parking facility is taken up later.

Analysis: A composite supply under section 2(30) requires two or more taxable supplies to be naturally bundled and supplied in conjunction in the ordinary course of business, with one being the principal supply. The parking facility in the present case was optional, separately priced, and could be availed independently by a flat purchaser even after completion of the project. The supply therefore lacked the character of a naturally bundled ancillary element of construction service. Since the right to use parking space was treated as a distinct service, the valuation benefit applicable to construction service could not be extended to it. The completion of the apartment transaction did not alter the character of the parking supply, and the cited clarification on preferential location charges in long-term lease of land was held inapplicable to this distinct service.

Conclusion: The right to use car parking space is a separate taxable supply and not part of a composite supply of construction of residential apartment services; it is taxable at 18%, and GST remains payable even where the apartment is sold after completion certificate or the parking facility is taken later.

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