Page 153 - GSTL_13th August 2020_Vol 39_Part 2

2020 ] IN RE : MACRO MEDIA DIGITAL IMAGING PVT. LTD. 239
(11) To substantiate this proposition further, the transactional matrix be-
tween the applicant and its customers is elaborated below.
Transactional Matrix between Applicant and the customer
(12) The Applicant states that purchase orders are placed by the custom-
ers on it, wherein the purchase orders clearly spell out the PVC ma-
terial required by the customer, nature of the product (lit or non-lit),
printing material on the PVC material and specifications of the said
product. The Applicant submits that the fact that purchase orders
placed on the Applicant by the customers mention such details
about supply, clearly establishes that the customer intends to pur-
chase whole trade advertisement from the Applicant and does not
intend to merely get PVC material (blank) printed from the Appli-
cant. Further, the said submission of Applicant is also substantiated
by the fact that customer of the Applicant wants to advertise its
products and such advertisement can only be done by the complete
trade advertisement, which constitutes a single indivisible economic
supply. Hence, it is submitted that the Applicant is supplying trade
advertisement to the customer as a whole.
(13) The Applicant submits that the economic supply of trade adver-
tisements involves multiple supplies, and that such supplies are so
interlinked and subsumed in one another that it is not possible to
artificially identify the individual supplies in the economic supply
of trade advertisements. Further, the Applicant is only supplying
trade advertisements as one economic supply, which is essentially a
movable property and eventually ‘goods’ in terms of Section 2(52)
of the CGST Act.
The supply of the trade advertisement amounts to a ‘composite supply’.
(14) The Applicant states that while enacting the CGST Act, the Legisla-
ture was mindful of the circumstances wherein one supply might
have two inseparable supplies of goods or services, or both. Hence,
in order to determine the nature of such supply, Legislature in its
wisdom has coined a concept of ‘composite supply’ under CGST
Act under Section 2(30) which reads as under :-
“(30) “composite supply” means a supply made by a taxable person
to a recipient consisting of two or more taxable supplies of goods or ser-
vices or both, or any combination thereof, which are naturally bundled
and supplied in conjunction with each other in the ordinary course of
business, one of which is a principal supply;
Illustration. - Where goods are packed and transported with insur-
ance, the supply of goods, packing materials, transport and insur-
ance is a composite supply and supply of goods is a principal sup-
ply”
(15) Supply consists of two or more supplies of goods, or services or both - the
Applicant submits that in the single economic supply of trade ad-
vertisements to the customers, the Applicant is making two sup-
plies, namely :-
(1) Supply of goods - Printed PVC material; and
(2) Supply of services - Printing of content supplied by customer
on PVC material.
GST LAW TIMES  13th August 2020  153