Page 165 - GSTL_21st May 2020_Vol 36_Part 3

2020 ] IN RE : SOLIZE INDIA TECHNOLOGIES PVT. LTD. 411
freight and insurance charges are part of the value of supply of power packs,
since the supply contract is a contract for supply of power packs and the value of
the contract is the sum total of the value of the power pack plus all charges
charged to the recipient for anything done till the goods are delivered to the re-
cipient.
9.2 Even if these supplies, i.e. supply of power pack and supply of
freight and insurance are distinct supplies, the same would be covered under the
definition of “composite supply” as per Section 2(30) of the CGST Act, 2017, as
the same are naturally bundled and supplied in conjunction with each other in
the ordinary course of business. The principal supply in the case is the supply of
power packs. Further Section 8 of the CGST Act, 2017 clearly states that the tax
liability on a composite supply shall be determined by treating them as a supply
of such principal supply. Hence going by this also, the composite supply of pow-
er pack and the supply of freight and insurance would be treated as “supply of
power packs” only as per Section 8 of the CGST Act, 2017.
9.3 In view of both the above paras, the supply of power packs and the
supply of freight and insurance services involved in such power packs shall be
treated as the “supply of power packs” and the applicable tax related to such
power packs and the time of supply would apply to the entire transaction as it
applies to the “supply of power packs”.
10. In view of the foregoing, we rule as follows
RULING
(1) The supply of power packs and the freight and insurance charges
would form part of the value of supply of power packs.
(2) The supply of commissioning/installation services supplied by the
applicant are independent services supplied by the applicant and is
independent of the supply of power packs.

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2020 (36) G.S.T.L. 411 (A.A.R. - GST - Kar.)
BEFORE THE AUTHORITY FOR ADVANCE RULING UNDER GST,
KARNATAKA
Dr. M.P. Ravi Prasad, Member (State Tax) and Shri Mashhood Ur Rehman
Farooqui, Member (Central Tax)
IN RE : SOLIZE INDIA TECHNOLOGIES PVT. LTD.
Advance Ruling No. KAR ADRG 25/2020, dated 23-4-2020
Software - Goods - Computer software provided by applicant pre-
developed or pre­designed software and made available through the use of
encryption keys, thereby satisfying all conditions of being ‘goods’ - Further,
such goods being used only with the aid of a computer are “computer soft-
ware” and more specifically covered under “Application Software” - Hence,
supply made by applicant covered under “supply of goods” and the goods
supplied are covered under HSN Code 8523 - Benefits of Notification Nos.
45/2017-C.T. (Rate) and 47/2017-I.T. (Rate) applicable to the supplies made if
the same are made to recipients covered under Column (2) and if the condi-
GST LAW TIMES  21st May 2020  165