Mixture of Dals and Spices is a "Mixed Supply" Taxable at 5% (Highest Rate Applicable)

Mixture of Dals and Spices is a “Mixed Supply” Taxable at 5% (Highest Rate Applicable)

Issue

How should a pre-packaged mixture of pulses and spices (sold as ‘Mixed Talimpu Dinusulu’) be classified under GST—whether as a composite supply or mixed supply—and what is the applicable tax rate when all individual ingredients attract the same rate of 5%?

Facts

The Product: The applicant, a trader, sells a product named ‘Mixed Talimpu Dinusulu’.
Composition: The pack contains a mix of:
- Channa Dal: 35%
- Urad Dal: 30%
- Mustard Seeds: 30%
- Jeera (Cumin): 5%
Individual Rates: Each of these ingredients, when sold separately, falls under different HSN codes (0713 for dals, 1207 for mustard, 0909 for jeera) but attracts the same GST rate of 5%.
Applicant’s Plea: The applicant argued that mixing these items does not alter their individual characteristics and sought a single classification and rate for the pack.

Decision (Ruling)

The Andhra Pradesh Authority for Advance Ruling (AAR) held that the product qualifies as a “Mixed Supply” under the GST Act.
Reasoning: The product is a bundle of distinct goods supplied for a single price, and they are not “naturally bundled” in the ordinary course of business (unlike a composite supply).
Taxability Rule: Under Section 8(b) of the CGST Act, a mixed supply is treated as a supply of that particular item which attracts the highest rate of tax.
Outcome: Since all the constituent ingredients (Dals, Mustard, Jeera) individually attract a tax rate of 5%, the highest rate applicable to the mix remains 5%. Consequently, the product is taxable at 5%.

Key Takeaways

Mixed Supply Definition: Any combination of goods sold for a single price that doesn’t fit the strict definition of “Composite Supply” (naturally bundled with a principal supply) falls into the “Mixed Supply” bucket.
The “Highest Rate” Principle: This is the golden rule for mixed supplies. Even if 95% of the pack is a 5% item and 5% is an 18% item, the entire pack is taxed at 18%. In this unique case, since all items were 5%, the liability remained flat.
Classification Logic: While the rate is clear, the HSN code for the mixed supply generally follows the HSN of the item that determines the highest tax rate.

AUTHORITY FOR ADVANCE RULING, ANDHRA PRADESH

Srikanth Industries, In re

K. Ravi Sankar and B. Lakshmi Narayana, Member

AAR No. 01/AP/GST/2025

MAY 26, 2025

A. Naga Raju, CA for the Applicant.

PROCEEDINGS

(Under sub-section (4) of Section 98 of Central Goods and Services Tax Act, 2017 and sub-section (4) of Section 98 of Andhra Pradesh Goods and Services Tax Act, 2017)

1. M/s Srikanth Industries, 11-53-27/2, Sobhanadri Lane, Vijayawada, (GSTIN No. 37AFUPN7632L1ZK) has filed an application in FORM GST ARA-01 under Section 97(1) of APGST Act, 2017 read with Rule 104 of CGST/APGST Rules.

2. At the outset we would like to make it clear that the provisions of CGST Act, 2017 and APGST Act, 2017 are in pari materia and have the same provisions in like matter and differ from each other only on a few specific provisions. Therefore, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act, 2017 would also mean reference to the corresponding similar provisions in the APGST Act, 2017.

3. It is observed that the queries raised by the applicant fall within the ambit of Section 97 of the GST ACT. The Applicant enclosed copies of challans as proof of payment of Rs. 5,000/- for SGST and Rs. 5,000/- for CGST towards the fee for Advance Ruling. The Applicant has declared that the questions raised in the application have neither been decided by nor are pending before any authority under any provisions of the GST Act.

4. Brief Facts of the case:

(i)

The applicant M/s Srikanth Industries, is used to sale all types of pulses, dals, flours, rava, rice, basmati rice, spices, and dry fruits etc.,. They have submitted that they want to sell ‘Mixed Talimpu Dinusulu’ which comes under the Tax rate of 5%, i.e., combination (Mix) of Chana dal, Urad dal, Jeera, Mustard in a Single Packet i.e., 50g, 100g 250g 500g and 1Kg. So, they requested for clarification on ‘HSN Code’ and ‘rate of tax’ for the ‘Mixed Talimpu Dinusulu’.

(ii)

They have submitted that in Talimpu Dinusulu each of the articles having the specific HSN Code and the tax rate but when mixed (nature of the articles not changed) we did not find the any HSN Code and tax rate under the GST.

i. Jeera	GST Rate: 5%
ii. Mustard	GST Rate: 5%
iii. Channa Dal	GST Rate: 5%
iv. Urad Dal	GST Rate: 5%

5. Questions raised before the authority:

The applicant sought advance ruling on the following:

Q) What is the tax rate and HSN code for mixed Talimpu Dinusulu consisting of the following ingredients with composition namely Channa dal of 35%, Urad dal of 30%, Mustard Seeds of 30% Jeera of 5% in a combination pack?

On Verification of basic information of the applicant, it is observed that the applicant is under State jurisdiction i.e, Park Road Circle, Vijayawada-1 Division. Accordingly, the application has been forwarded to the jurisdictional officer and a copy marked to the Central Tax authorities to offer their remarks as per Sec. 98(1) of CGST /APGST Act 2017.

In response, remarks are received from the State jurisdictional officer concerned stating that no proceedings lying pending on the issue, for which the advance ruling sought by the applicant.

6. Applicant’s Interpretation of Law:

(i)

. Talimpu Dinusulu Tax Rate will be 5 % because the each of the article used in this belongs to 5 % tax rate. We are simply packing the 4 types of goods in single packet and not changing the nature of the product

7. Personal Hearing:

The proceedings of Personal Hearing was conducted on 23.04.2025, for which the authorized representative, Sri A Naga Raju, Charted Accountant has appeared and reiterated the facts narrated in the application contending that the applicant is mixing Jeera, mustard, Chana dal and Urad dal which is used for tempering in cooking. Though the rate of tax for all the four ingredients used in ‘Mixed Talimpu Dinusulu’ is 5%, but HSN codes are different for each of the ingredient. Therefore, he sought clarification on HSN code and rate of tax to be used in the tax invoices.

Further, vide letter dated 22.4.2025, they have declared the Mixing %, HSN Code and Tax Rate of the 4 raw materials used in the manufacture of the Tempering Seeds or Talimpulu as under:

Article Name	Mixing%	HSN Code	Tax Rate
Channa Dal	35%	07139010	5%
Urad Dal	30%	07133100	5%
Mustard Seeds	30%	12075090	5%
Jeera	5%	09093129	5%

Further, the Authorised Representative during the personal hearing submitted a sample packet of the product ‘Mixed Talimpu Dinusulu’.

8. Discussion and Findings:

We have carefully gone through the submissions made by the applicant in the advance ruling application, additional submissions made by the Authorised representative during the course of Personal hearing.

Individual Component Classifications and GST Rates of Mixed Products (Talimpu Dinusulu):

The applicant intends to mix Jeera, Mustard, Channa Dal, and Urad Dal without altering their individual characteristics. The HSN Code and GST rates of each individual component in ‘Mixed Talimpu Dinusulu’ as per Notification No. 2/2017-Central Tax (Rate) dated 28th June 2017, is as under:

Name of the Good	HSN Code	GST Rate
Jeera	0909,	5%
Mustard	1207	5%
Channa Dal	0713	5%
Urad Dal	0713	5%

Section 2(74) of the CGST Act defines mixed supply as follows:

“Mixed supply” means two or more individual supplies of goods or services, or any combination thereof, made in conjunction with each other by a taxable person for single price where such supply does not constitute a composite supply.

Illustration: A supply of package consisting of canned foods, sweets, chocolates, cakes, dry fruits, aerated drinks and fruit juices when supplied for a single price is a mixed supply. Each of these items can be supplied separately and is not dependant of any other. It shall not be a mixed supply if these items are supplied separately;

Further, Section 8 of CGST Act, 2017 defines taxability of Composite and Mixed Supplies and read as follows:

“The tax liability on a composite or a mixed supply shall be determined in the following manner, namely:

(a) a composite supply comprising two or more supplies, one of which is a principal supply, shall be treated as a supply of such principal supply: and

(b) a mixed supply comprising two or more supplies shall be treated as a supply of that particular supply which attracts the highest rate of tax.”

The above provision clearly specified that a mixed supply containing more than two supplies shall be treated as a supply of that particular supply which attracts the higher rate of tax in the mix supply. Hence, it is required to use the HSN code of the particular supply which attracts higher rate of tax among all the taxable supplies containing in a Mixed supply.

However, in the present case, in ‘Mixed Talimpu Dinusulu’, the product the applicant intends to prepare and sold, all the ingredients are attracting similar rate of tax i.e, 5%. But, while preparing the product ‘Mixed Talimpu Dinusulu’, the applicant is using ‘chana dal’ at higher proportion i.e., at 35%, than that of the remaining ingredients ‘urad dal’ and ‘mustard seeds’ each at 30% and ‘Jeera’ at 5%. Therefore, we hold that product ‘Talimpu Dinusulu’ qualifies as a mixed supply comprising two or more individual supplies under Section 8(b) of CGST Act, 2017. Accordingly, it shall be classifiable as the supply that attracts the highest rate of tax.

RULING

Question: What is the tax rate and HSN code for mixed ‘Talimpu Dinusulu’ consisting of the following ingredients with composition namely Channa dal of 35%, Urad dal of 30%, Mustard Seeds or 30% Jeera of 5% in a combination pack?

Answer: The product ‘Mixed Talimpu Dinusulu’ qualifies as a mixed supply as it consists of two or more individual supplies. It shall be classifiable as the supply of the ingredient that attracts highest rate of tax.