GST Classification of Bundled Printing Supplies: Maharashtra Advance Ruling
The Maharashtra Authority for Advance Ruling decided that bundling printing consumables is a mixed supply, not a composite supply, requiring the highest tax rate.
- Ruling
- NO.GST-ARA- 38/17-18/2024-25/B-641, Mumbai, dt. 30.12.2025
- Dated
- 30 Dec 2025
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- HP India asked if their printing supply bundle was a composite supply.
- The Authority ruled the bundle is a mixed supply, not composite.
- Mixed supplies must be taxed at the highest rate among the included items.
- The ruling confirms that independent availability of items prevents composite supply classification.
In short
HP India asked the Maharashtra Authority for Advance Ruling (AAR) how to classify their printing supplies, which include ink and other parts sold together under a single contract. They argued these items were naturally bundled, but the Authority disagreed because customers could also buy these items separately. Because they are not naturally bundled, the tax department classified the package as a mixed supply.
What has changed
How it worked before
Businesses often assumed that if items were sold together under a single contract or pricing model, they could be treated as a single composite supply taxed at the rate of the main item.
What has changed
The Authority decided that if items in a bundle can be bought separately, the bundle is a mixed supply. This means you must apply the highest GST rate found among any of the items in your package to the entire bundle, rather than the rate of the primary item.
Who this affects
Businesses that sell packages of different goods for a single price, especially where those goods could also be purchased individually.
An example
Imagine a stationery company sells a 'Starter Kit' containing a high-tax printer and low-tax paper for one price. If the company also sells the printer and paper separately, this ruling suggests the kit is a mixed supply. The company would likely have to charge the higher printer tax rate on the entire kit. They cannot claim it is a composite supply just because it is convenient to sell them together.
What you should do
Review your bundled product offerings to see if items are sold independently. Remember that this ruling only applies to the company that asked; it is not a law that automatically changes how your business must pay GST. If you are unsure about your tax classification, consult a professional to assess your specific contracts.
If you do nothing
If you incorrectly classify a mixed supply as a composite supply, you will likely underpay your GST. Tax officers may issue a notice for the tax shortfall, plus interest and penalties. Relying on a ruling meant for another company provides no legal protection if your specific facts differ.
The terms explained
- Composite supply
- A bundle of goods or services that are naturally sold together in the ordinary course of business, where one item is the main supply.
- Mixed supply
- A combination of two or more individual goods or services sold together for a single price that does not qualify as a composite supply.
- Principal supply
- The main item in a bundle that gives the package its essential character.
The ruling in detail
Authority for Advance Ruling
M/s. HP India Sales Private Limited
NO.GST-ARA- 38/17-18/2024-25/B-641, Mumbai, dt. 30.12.2025 · Maharashtra
Questions before the authority
- Classification of ElectroInk supplied along with consumables under GST.
- Determination of time and value of supply of ElectroInk with consumables under the indigo press Contract.
Facts
The applicant supplies HP Indigo digital printing presses and associated consumables (ElectroInk, imaging plates, blankets, etc.) to authorized resellers. These supplies are provided under a 'click model' where the reseller is billed based on the number of prints generated, rather than for individual items. The applicant contended that this bundle constitutes a composite supply with ElectroInk as the principal supply.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of ElectroInk with consumables | Mixed supply Attracts the highest rate of tax amongst all goods in the supply |
| Time and value of supply | Time: earlier of invoice or payment date; Value: transaction value per invoice Determined under Section 12(2) and Section 31(4) of the CGST Act |
The Authority held that the supply of ElectroInk along with consumables and operator parts is a mixed supply, not a composite supply. Consequently, the supply is classified as a mixed supply, attracting the highest rate of tax applicable among the constituent goods. The time of supply is determined as the earlier of the date of invoice or the date of receipt of payment, and the value is the transaction value as reflected in the tax invoice.
Reasoning
The Authority reasoned that the goods are not naturally bundled in the ordinary course of business, as customers have the option to purchase items separately under an 'A La Carte' model. Furthermore, no single item in the bundle qualifies as a 'principal supply' because all components are equally indispensable for the printing process. Therefore, the transaction fails the criteria for a **composite supply** under Section 2(30) and instead meets the definition of a **mixed supply** under Section 2(74) of the CGST Act. The Authority also noted that the billing mechanism does not override the statutory classification of the underlying goods.
Provisions relied on
- Section 2(30) of the CGST Act
- Section 2(74) of the CGST Act
- Section 2(32) of the CGST Act
- Section 8 of the CGST Act
- Section 12(2) of the CGST Act
- Section 15 of the CGST Act
- Section 31(4) of the CGST Act
For the practitioner
This ruling serves as a warning for businesses that bundle distinct goods under a single price model, even if the bundle is standard industry practice. It clarifies that the existence of an alternative procurement option (like the 'A La Carte' model here) can be fatal to a **composite supply** claim. Practitioners should note that the Authority prioritizes the ability to supply goods independently over the commercial convenience of a bundled pricing model.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/2-ms_hp_india_sales.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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