SGST Advance Ruling Authority

GST – Telangana AAR - Composite supply or Mixed supply - Applicant are making supplies to integrate at Integral Coach Factory by way of design, development, manufacture, supply, testing and commissioning of 25 KV AV microprocessor controlled IGBT wherein the payment is to be released for complete rake set and not for part supplies - whether subject supply comes under composite supply or mixed supply or supply of individual component parts - whether all these items which are related to Locomotive parts can be classified under a single HSN Code of 8607 as Locomotive parts considering the end usage of the product irrespective of product / item description – HELD - the contract between the applicant and the Integrated Coach Factory is for a bundled supply of goods - the supply made by the applicant against the purchase order of the Integrated Coach Factory is a mixed supply and the rate of tax applicable is the highest rate of tax applicable to the particular goods constituting the mixed supply - if the goods supplied by the applicant in the purchase order have to be treated as "parts of Railway or Tramway" they should qualify for all the conditions - Applying principle of Noscitur a sociis it is seen from the purchase order none of the goods supply fall under this entry. They are also not essential component without which the whole cannot function. Therefore the supplies made under the referred purchase order to Integrated Coach Factory do not fall under HSN 8607

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