Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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AAAR determined that supply of DOMS A1 pencils with sharpener constitutes a mixed supply under CGST Act, 2017, not a composite supply, as items are not naturally bundled or supplied in conjunction during ordinary business. The appellant's argument to apply General Interpretative Rules (GIR) for classification was rejected as Section 8(b) of CGST Act prevails when unambiguous. For mixed supplies, the HSN code attracting higher tax rate among component supplies (8214, 9608, or 9609) applies. Consequently, the supply attracts 12% tax rate based on the highest applicable rate among individual components. Appeal dismissed.
AAAR determined that supply of DOMS A1 pencils with sharpener constitutes a mixed supply under CGST Act, 2017, not a composite supply, as items are not naturally bundled or supplied in conjunction during ordinary business. The appellant's argument to apply General Interpretative Rules (GIR) for classification was rejected as Section 8(b) of CGST Act prevails when unambiguous. For mixed supplies, the HSN code attracting higher tax rate among component supplies (8214, 9608, or 9609) applies. Consequently, the supply attracts 12% tax rate based on the highest applicable rate among individual components. Appeal dismissed.
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