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GST – Karnataka AAR - Composite Supply - Contract for manufacture and supply of Standard Gauge Intermediate Cars along with integration with installation and commissioning, training, supervision and maintenance, supply of spares etc. to Bangalore Metro Rail Project – various cost centres of the applicant is making separate supplies based on their scope independent of each other and the obligations and responsibilities of each of the Cost Centres is based on their independent scope of works - Whether the supplies made by various Cost Centres of applicant are independent supplies of goods and services or composite supply with principal supply of goods – HELD – the contract is a single contract for both supply of goods and also for services related to those goods supplied, like installation, integration, commissioning etc. and splitting of the entire contract is for the purposes of milestones in the completion of the contract and is a single continuous chain - The Contract agreement clearly states that the contract is a single contract involving supply of goods and services. Further, the contract cannot be separated and awarded to different persons and since the nature of the spares and services are exclusive to the main supply, it cannot but be awarded to the same person - the supplies made under Cost Centre C is of goods, Cost Centres D and E are related to services and supplies made under Cost Centre G is related to the spares - supply covered under Cost Centre H, being optional, cannot be treated as a part of the contract of supply - Cost Centre C to G would form a composite supply under clause 30 of Section 2 of CGST Act as the supply involves supply of intermediate cars being the principal supply, the entire supply done under Cost Centers A to E would be deemed to be the supply of intermediate cars - Since the agreement itself states that the milestones are only artificial creations to enable cash flows to the applicant, this is treated as a naturally bundled supply with the supply of intermediate cars. Hence Supply under Cost Centre C to G would form a composite supply and the entire supply would amount to composite supply of intermediate cars as per section 8 of the CGST Act and the time of supply is the issuance of invoice in the present case
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