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21 September 2021

Supply of coaching service along with supply of goods shall be considered as composite supply and not mixed supply: AAR Rajasthan.

In the matter of Symmetric Infrastructure (P.) Ltd., In Re J.P. Meena and M.S. Kavia [2021][130 taxmann.com 136], the Applicant is engaged in supplying services of coaching to students which also includes along with coaching, supply of goods/printed material/test papers, uniform, bags and other goods to students. Such supplies are not charged separately but a consolidated amount is charged, the major component of which is imparting of coaching. Since the applicant supplied the goods i.e. printed material, text paper, uniform, bags to the students etc. and as well as supply of services i.e. coaching/Training to the student. As such supplies are not charged separately but a consolidated amount is charged by the applicant.

Now the question under consideration was that whether the supply, supplied by the applicant to the students to be a supply of goods or supply of service and if the said supply is supply of service then whether such supply shall be considered as composite supply

The sub-section (1) of the Section 7 of the of the CGST Act, 2017 states that the activities to be treated as supply of goods or supply of services as referred to in Schedule II. In the instant case, the applicant is providing coaching service to its enrolled students for as consideration which will be a lump sum amount for both goods and services. Therefore, transaction of supply of coaching service for a consideration falls under the ambit of "Supply of service"

Further, in the instant case, the applicant along with coaching services provides goods in the form of uniforms, bags, study material etc. Supply of goods is a part of supply of service shall qualify as composite supply'. The principal supply being the supply of coaching service to the students, tax on such supply shall be levied accordingly.

Further, the question about the value of supply has also been discussed in the advance ruling.

As per Sec 15(2)(b), the value of supply shall include-

“any amount that the supplier is liable to pay in relation to such supply but which has been incurred by the recipient of the supply and not included in the price actually paid or payable for the goods or services or both.”

In the instant case, applicant has been incurring the cost of goods supply to the students i.e. Bags, study material etc. Therefore, in light of the provisions of Sections 15(2)(b) of the Act, the values of goods are part of the value of services provided by the applicant and charged a consolidate amount to the students. Therefore, the consolidated value for which tax invoice is issued shall be the taxable value.