In re Zydus Wellness Products Limited (GST AAR West Bengal)
The applicant filed an application before the GST Authority for Advance Ruling, West Bengal, under Section 97(1) of the Central Goods and Services Tax Act, 2017 and the West Bengal Goods and Services Tax Act, 2017, seeking clarification on the tax treatment of bundled supplies of Glucose Powder (HSN 1702) and Nutritional Beverage Mix (HSN 1901), both taxable at 5 percent. The products were supplied either as standalone items or as combo packs bundled with plastic sippers or shakers provided without separate consideration. The applicant contended that such supplies constituted “composite supply” under Section 2(30) of the CGST Act, with the beverage mix being the principal supply under Section 2(90), thereby attracting GST at 5 percent under Section 8(a). Alternatively, it submitted that if not treated as composite supply, the free accessories would not amount to “supply” under Section 7 in the absence of consideration, subject to Schedule I, and that proportionate reversal of input tax credit under Section 17(5)(h) would be undertaken. The questions raised were admitted, as they fell within Section 97(2)(a) and (d), and no objection was raised by the concerned officer regarding admission.
The Authority scheduled hearings on 03.02.2026 and later on 13.02.2026 after granting adjournment upon the applicant’s request. During the personal hearing on 13.02.2026, the authorised representative stated that the applicant intended to withdraw the advance ruling application. A written submission explained that after conducting a detailed commercial and financial evaluation of the business model described in the application, the applicant found the model commercially unviable. It was submitted that continuation of the advance ruling proceedings would not serve any purposeful commercial or business objective. The withdrawal request was also communicated by email on the same date. In view of these submissions, the Authority disposed of the application as withdrawn. The order also stated that an appeal against the ruling, if any person is aggrieved, may be filed before the West Bengal Appellate Authority for Advance Ruling within thirty days in accordance with Section 100 of the GST Act and the prescribed rules and regulations.
