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Dear sir/madam,
Whether supply of school uniform, shoes & bags to be treated as composite supply and hence eligible to claim exemption under Educational service (or) to be treated as mixed supply and therefore liable for GST Levy? Kindly clarify and discuss any case laws / Advance ruling are available in this regard.
Thank you.
of Supply of books is exempt under GST. However, uniform, stationery, and other non-academic related supplies are taxable under GST.
Coaching services provided by third parties like the musical instrument, computers, sports equipment and after-school activities offered directly by third parties are also taxable.
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Supply of school uniform, shoes, bags etc. cannot be treated as composite supply. No question of mixed supply as well. All are separately classifiable under Headings/Chapter/HSN attracting GST.
If you are supplying all those in one combo pack for a single price, it can be treated as mixed supply and GST rate will be highest of the all item. If not, then there will be separate GST rate with separate HSN. No exemption is there except books. Kasturi sir already explained very well. I fully agree with view.
In my opinion, there is a scope for arguing that supply of uniform, shoes & bags to students to whom education service is provided, is naturally bundled and hence is a composite supply for the following reasons:
1. Generally, the students are mandated to purchase text books, note books, uniform, shoes, stationary etc... along with education services from the school itself.
2. A non-student is not allowed to buy books, uniforms, and stationary from the school. These are generally to be provided to the students of the particular school only.
3. From the student/service recipients' perspective, it is seen a single bundle.
4. Many private schools are doing this practice.
5. All the above goods are integral to one overall supply i.e. education service.
That being said, this position may lead to litigation also, and one has to take a call based on all facts and circumstances.
I agree with views of Shri Padmanathan Ji given above (including his views that one needs to take a such call only after through checking of the fact & circumstances of every case)!
Needless to say that those views are with the understanding of supplier of 'school uniform, shoes & bags' to the students is the educational institution (& not third party vendor/s suppling such goods directly to the students) as defined vide Para 2 (y) of Notification No. 12/2017- Central Tax (Rate).
These are ex facie views of mine and the same should not be construed as professional advice/suggestion.
Dear Amit Ji,
Thank you for clarifying my views. It is a pleasure to have your comment after a short while.
Regards
Thank you all experts for your support 🙏🏻
The school uniform, bag and shoes generally not clubbed with education services.
The education institutes provide separate services such as Education services for which they charge tution fee & for goods such as stationary items including books, uniform, bags and shoes, they charge separate amount.
Mixed supply or composite supply can be treated if -
-supplying at the same time,
-to same receiver
-not a combination of services and goods
-on a Single Price
-naturally bundled
other factors may be there.
If Education institute are providing education services it is exempt , but if an individual supplier providing school bags, uniform and shoes and separately charging the amount, then GST is payable. In common, it is also not possible, becuase of sizes vary in terms of uniform and shoes.
Sh.Pawan Kumar Ji,
Your argumentation is full of logical as well as legal force.
Learned Pawan sir,
kindly help me understand where it is provided that a combination of supply of goods and supply of services is barred to be composite/ mixed supply. Also, for composite supply there is no requirement of single price. Pls consider this view also.
Books are given by schools from the fees paid for education. School uniform is told by school to be purchased from X vendor. A tie up is made by school with that vendor.
Sometime the vendor delivers the uniform at the school office and parents are asked to collect it. The school asks parent to make payment directly to vendor or receives the payment only to give that amount to that vendor.
Both are individual supply I.e. supply of books and uniform.
Sir, as per my view, there is no such example of goods and services in composite supply/mixed supply except works contract.
Reading of definition of 'composite supply' as covering situation of two or supplies for 'single price' exclusively is wrong (as consideration can be either combined or separate, though there will always be consideration for each supply), in my humble view.
This is more so when there is no such requirement prescribed under law (& when same being specifically prescribed for 'mixed supply') as well as taking into account the objects behind Section 8.
For my reasoning behind above views, one can refer to discussion we had under Issue-ID: 118614, bearing subject-line as 'Composite or mixed supply'.
These are ex facie views of mine and the same should not be construed as professional advice / suggestion.
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