Mixed Supply treatment for click-based bundled goods; highest constituent tax rate applies and time/value follow invoice or payment.

The bundled supply of ElectroInk with consumables and operator parts is a mixed supply because no single component is shown to be the principal supply nor naturally bundled in the ordinary course of business; accordingly the highest rate applicable to any constituent applies to the package. Where the supplies are recurrent under a click-based contract, they qualify as continuous supply and the time of supply is the earlier of invoice issuance or receipt of payment, while the value is the transaction value as reflected in the periodic tax invoice issued in accordance with invoice rules.

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Issues: (i) Whether the supply of ElectroInk supplied along with consumables and operator parts under the HP Indigo 'click' arrangement qualifies as a composite supply or a mixed supply for GST purposes; (ii) Determination of the time and value of supply for ElectroInk with consumables under the Indigo press contract.

Issue (i): Whether the bundled supply of ElectroInk with consumables and operator parts is a composite supply under Section 2(30) of the Central Goods and Services Tax Act, 2017 or a mixed supply under Section 2(74) of the Central Goods and Services Tax Act, 2017.

Analysis: The statutory tests for composite supply require (a) two or more taxable supplies, (b) natural bundling, (c) supply in conjunction in the ordinary course of business, and (d) existence of a principal supply. Evidence and contract terms were examined: the supply comprises multiple taxable goods; the contractual arrangements permit both a tier (click) program and an a-la-carte option; consumables and certain machine parts have differing lifespans and can be procured separately; industry materials and customer declarations show prevalence of click pricing but do not establish that elements are unavailable separately or that the bundling is compelled by market practice; the Chartered Engineer's certificate describes technical interdependence but acknowledges all components as indispensable rather than identifying a clear principal element; CBIC guidance and illustrations require objective predominance or ancillary relationship to identify a principal supply.

Conclusion: The supply does not satisfy the requirement of a composite supply because no single component qualifies as the principal supply and the bundle is not demonstrated to be naturally bundled in the ordinary course of business; the supply is a mixed supply within the meaning of Section 2(74) of the Central Goods and Services Tax Act, 2017 and thus the highest rate of tax applicable to any constituent supply applies to the entire package.

Issue (ii): What is the time and the value of supply for ElectroInk with consumables under the HP Indigo press contract, given the billing and contractual arrangements.

Analysis: The contract provides for continuous/recurrent supply with periodic invoicing under a click-based billing mechanism. Section 2(32) defines continuous supply of goods; Section 12(2) prescribes that time of supply of goods is the earlier of invoice issuance or receipt of payment; Section 31(4) governs invoice timing for continuous supplies where successive statements or payments are involved; Section 15 identifies transaction value as the basis for value determination. The contractual practice of issuing consolidated monthly invoices based on clicks aligns with the statutory scheme for continuous supplies and invoicing.

Conclusion: For the impugned supplies (treated as continuous supply), the time of supply is the earlier of the date of issue of invoice or the date of receipt of payment; the value of supply is the transaction value as reflected in the tax invoice issued in accordance with Section 31(4) of the Central Goods and Services Tax Act, 2017.

Final Conclusion: The Authority has concluded that the HP Indigo click-based bundled supplies constitute a mixed supply (not a composite supply) and that, being a continuous supply invoiced periodically, time of supply is the earlier of invoice date or payment date and value is the transaction value shown in the tax invoice.

Ratio Decidendi: Where bundled goods lack a demonstrable principal element and can be procured or supplied separately, the transaction qualifies as a mixed supply under Section 2(74) of the Central Goods and Services Tax Act, 2017 and, for continuous supplies invoiced periodically, time of supply is determined by Section 12(2) with value being the transaction value under Section 15 read with Section 31(4).

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